- 7 -
Discussion
The evidence in these cases is clear that (except for the
May 2, 1995, and the December 9, 1999, settlements relating to
petitioners’ 1980, 1981, and 1982 tax liabilities that are
mentioned above) no settlements were entered into between
petitioners and respondent with regard to petitioners’ Federal
income tax liabilities for the years 1980 through 1985.
Petitioners’ attempt to have the $130,836 in payments that they
made on December 27, 1988, treated as a binding and final
settlement of all of petitioners’ Federal income tax liabilities
relating to the White Rim and Syn-Fuel partnerships for the years
1980 through 1985, or for any portion thereof, is rejected.
Binding settlement agreements may be entered into between
taxpayers and respondent. To constitute, however, a binding
settlement agreement of a Federal tax controversy, the taxpayers
and respondent’s representatives, among other things, must comply
generally with contract principles such as offer and acceptance
and must objectively manifest mutual assent to the essential
terms of the purported settlement agreement. See Dorchester
Indus. v. Commissioner, 108 T.C. 320, 329-330 (1997), affd. 208
F.3d 205 (3d Cir. 2000).
As we have found, with regard to the amounts in controversy,
petitioners never accepted the terms of any pending settlement
from respondent. To the contrary, after making the payments
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011