Legal Opinion

Gladden v. Comm'r

United States Tax Court

Decided June 27, 2003No. 16932-97Published

Held: Where petitioners made a "qualified offer" under sec. 7430(c)(4)(E), I.R.C., on a substantive tax adjustment and thereafter litigation occurred and court determinations were made on arguments or issues relating to the substantive tax adjustment and where the parties ultimately entered into a settlement of the substantive tax adjustment, the "settlement limitation" on qualified offers that is set forth in sec. 7430(c)(4)(E)(ii)(I), I.R.C., is not applicable.

1Opinion of the Court

WILLIAM T. GLADDEN AND NICOLE L. GLADDEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Gladden v. Comm'r

No. 16932-97

United States Tax Court

120 T.C. 446; 2003 U.S. Tax Ct. LEXIS 18; 120 T.C. No. 16;

June 27, 2003, Filed

Gladden v. Commissioner, 112 T.C. 209, 1999 U.S. Tax Ct. LEXIS 18 (1999)

Judgment entered herein with regard to water rights adjustment was not to be regarded as issued merely pursuant to settlement. Petitioners' qualified offer with regard to water rights adjustment was not limited by settlement limitation on qualified offers that is set forth in section…

2Cases cited7 opinions

  1. Marek v. ChesnySupreme Court of the United States · 1985
  2. Delta Air Lines, Inc. v. AugustSupreme Court of the United States · 1981
  3. Haas & Assocs. Accountancy Corp. v. Comm'rUnited States Tax Court · 2001
  4. William T. Gladden Nicole L. Gladden v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2001
  5. Gladden v. Comm'rUnited States Tax Court · 1999

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