Legal Opinion

Dixson Int'l Service Corp. v. Commissioner

United States Tax Court

Decided May 17, 1990No. 22832-88Published

R took several alternative positions in the notices of deficiency and answers, but did not explicitly identify them as such. When these cases were called for trial, the parties filed stipulations of settled issues and requested additional time to make the computations necessary for entry of decisions. Neither the stipulations of settled issues nor the oral representations of the parties made any reference to litigation costs.

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R took several alternative positions in the notices of deficiency and answers, but did not explicitly identify them as such. When these cases were called for trial, the parties filed stipulations of settled issues and requested additional time to make the computations necessary for entry of decisions. Neither the stipulations of settled issues nor the oral representations of the parties made any reference to litigation costs. The stipulations of settled issues involved substantial concessions by both parties. The final computations show that Ps' combined net tax deficiencies, pursuant to the…

1Opinion of the Court

Dixson International Service Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent; Dixson, Inc. and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent

Dixson Int'l Service Corp. v. Commissioner

Docket Nos. 22829-88,1

22832-88

United States Tax Court

94 T.C. 708; 1990 U.S. Tax Ct. LEXIS 48; 94 T.C. No. 43;

May 17, 1990, Filed

R took several alternative positions in the notices of deficiency and answers, but did not explicitly identify them as such. When these cases were called for trial, the parties filed stipulations of settled issues and requested additional…

2Cases cited24 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Sher v. CommissionerUnited States Tax Court · 1987
  3. Leopold Z. Sher and Karen B. Sher v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
  4. Minahan v. CommissionerUnited States Tax Court · 1987
  5. Sokol v. CommissionerUnited States Tax Court · 1989

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