Johnston v. Comm'r
United States Tax Court
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 amount of net operating losses (NOLs) sustained in the 1988, 1990, 1993, and 1995 tax years.
Read the full summary
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 amount of net operating losses (NOLs) sustained in the 1988, 1990, 1993, and 1995 tax years. R refused to allow such a reduction, claiming that R's acceptance of Ps' qualified offer prevented Ps from reducing the agreed-upon amounts. Held: The parties entered into a contract to settle the docketed cases, as evidenced by Ps'…
1Opinion of the 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
Johnston v. Comm'r
No. 26005-96; No. 2266-97
United States Tax Court
122 T.C. 124; 2004 U.S. Tax Ct. LEXIS 7; 122 T.C. No. 6;
February 11, 2004, Filed
Johnston v. Commissioner, 119 T.C. 27, 2002 U.S. Tax Ct. LEXIS 40 (2002)
Commissioner's motion for summary judgment granted.
Ps made a qualified offer, pursuant to sec. 7430, I. R. C.,
to resolve Ps' tax liabilities for…
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
3 more not listed; retrieve them via the Exa API.