Nault v. United States

STAHL, Senior Circuit Judge.

Plaintiff-appellant Richard M. Nault appeals the district court’s decision denying his motion for summary judgment and granting summary judgment in favor of the United States. Nault argues that the district court erred in its interpretation of several agreed judgments entered by the Tax Court (“the Tax Court decisions”), embodying the terms of a settlement between the Internal Revenue Service (“IRS”) and Frederick H. Behrens, as Tax Matters Partner (“TMP”), regarding the proper tax treatment of several agriculture-related limited partnerships organized by American…