Dorchester Indus. v. Comm'r
United States Tax Court
R has moved for entry of decisions based on an agreement with Ps to settle these cases. Two Ps argue that they never agreed to settle these cases and, even if they did, they have repudiated that agreement.
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R has moved for entry of decisions based on an agreement with Ps to settle these cases. Two Ps argue that they never agreed to settle these cases and, even if they did, they have repudiated that agreement. Held: Ps entered into a settlement agreement with R. R's motions for entry of decision will be granted with respect to all dockets (except with regard to W). Cole v. Commissioner, 30 T.C. 665 (1958), affd. 272 F.2d 13 (2d Cir. 1959), will not be followed to the extent that it indicates that a party to a settlement agreement that is not filed as a stipulation may repudiate that agreement up…
1Opinion of the Court
Halpern, Judge:
Respondent has determined deficiencies in Federal income tax and additions to tax in the following cases:
Docket No. Petitioner(s) Tax years
20515-93 Dorchester Industries Inc. 1981, 1982, 1985 1986
20572-93 Frank Wheaton, Jr., and Mary Wheaton 1979-1988
27121-93 Frank Wheaton, Jr., and Mary Wheaton 1989
23092-94 Frank Wheaton, Jr., and Mary Wheaton 1990
Respondent has moved for entry of decision with respect to each of those cases. Subsequent to respondent’s moving for entry of decisions in the cases at docket Nos. 20572-93, 27121-93, and 23092-94, respondent and petitioner Mary…
2Cases cited16 opinions
- Swift & Co. v. United StatesSupreme Court of the United States · 1928
- Teodore Dorotee Autera v. Manuel Dudley Robinson, Anthony C. Autera v. Manuel Dudley RobinsonCourt of Appeals for the D.C. Circuit · 1969
- Williams v. First Nat. Bank of Pauls ValleySupreme Court of the United States · 1910
- Olefins Trading, Inc. v. Han Yang Chem CorporationCourt of Appeals for the Third Circuit · 1993
- Stamm International Corp. v. CommissionerUnited States Tax Court · 1988
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3Cited by58 opinions
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- Bankamerica Corp. v. CommissionerUnited States Tax Court · 1997
- Johnston v. Comm'rUnited States Tax Court · 2004
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