T.C. Memo. 2007-5
UNITED STATES TAX COURT
RICHARD NICHOLS AND LISA NICHOLS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1384-05L. Filed January 9, 2007.
David B. Shiner, for petitioners.
Gregory J. Stull, for respondent.
MEMORANDUM OPINION
HOLMES, Judge: In 2001, Richard Nichols and his wife Lisa
reached a compromise with the IRS on their 1994 tax liability.
The Nicholses agreed that the IRS could immediately assess and
collect an agreed amount, but they reserved the right to sue for
a refund. The Nicholses then learned that they had net operating
losses from later years. They asked the Commissioner to let them
use these losses to reduce their 1994 tax liability; they also
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