Legal Opinion
Thomas E. Johnston and Thomas E. Johnston, Successor in Interest to Shirley L. Johnston v. Commissioner
United States Tax Court
Decided February 11, 2004No. 26005-96, 2266-97Unknown
1Opinion of the Court
122 T.C. No. 6
UNITED STATES TAX COURT THOMAS E. JOHNSTON and THOMAS E. JOHNSTON, SUCCESSOR IN INTEREST TO SHIRLEY L. JOHNSTON, DECEASED, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent* THOMAS E. JOHNSTON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 26005-96, 2266-97. Filed February 11, 2004 Ps made a qualified offer, pursuant to sec. 7430, I.R.C., to resolve Ps’ tax liabilities for the 1989, 1991, and 1992 tax years. R accepted Ps’ qualified offer, without negotiation. Thereafter, Ps sought to reduce the amounts stated in the qualified offer by the…
2Cases cited8 opinions
- Dorchester Indus. v. Comm'rUnited States Tax Court · 1997
- Cloes v. CommissionerUnited States Tax Court · 1982
- Amile A. And Parvane S. Korangy v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1990
- General Signal Corp. v. CommissionerUnited States Tax Court · 1995
- Johnston v. Comm'rUnited States Tax Court · 2004
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