Brinkman v. Commissioner
United States Tax Court
R offered to settle issues regarding Ps' investment in various partnerships by allowing "out-of-pocket" expenditures for the taxable years at issue. The offer was communicated to Ps' representative. Ps, through their representative, entered into closing agreements with R wherein the "out-of-pocket" expenditures were allowed for the 1982 taxable year. Ps also had "out-of-pocket" expenditures for years subsequent to 1982 which were not incorporated into the closing agreement.
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R offered to settle issues regarding Ps' investment in various partnerships by allowing "out-of-pocket" expenditures for the taxable years at issue. The offer was communicated to Ps' representative. Ps, through their representative, entered into closing agreements with R wherein the "out-of-pocket" expenditures were allowed for the 1982 taxable year. Ps also had "out-of-pocket" expenditures for years subsequent to 1982 which were not incorporated into the closing agreement. Sec. 7121, I.R.C. 1954, would permit the setting-aside of a closing agreement upon a showing of fraud or malfeasance, or…
1Opinion of the Court
ROBERT W. and MARY A. BRINKMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent; JOHN GRIMES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Brinkman v. Commissioner
Docket Nos. 23703-87; 23706-87.
United States Tax Court
T.C. Memo 1989-217; 1989 Tax Ct. Memo LEXIS 218; 57 T.C.M. (CCH) 331; T.C.M. (RIA) 89217;
May 4, 1989; As corrected May 8, 1989
R offered to settle issues regarding Ps' investment in various partnerships by allowing "out-of-pocket" expenditures for the taxable years at issue. The offer was communicated to Ps' representative. Ps, through their…
2Cases cited15 opinions
- Lifter v. CommissionerUnited States Tax Court · 1973
- Helvering v. KehoeSupreme Court of the United States · 1940
- Bankers' Reserve Life Co. v. United StatesUnited States Court of Claims · 1930
- Wolverine Petroleum Corp. v. CommissionerCourt of Appeals for the Eighth Circuit · 1935
- Aetna Life Ins. Co. v. EatonCourt of Appeals for the Second Circuit · 1930
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3Cited by1 opinion
- Estate of Powell v. United StatesDistrict Court, W.D. Virginia · 2001