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The closing agreements state:
This agreement is final and conclusive except:
(1) The liability it relates to may be reopened in the
event of fraud, malfeasance, or misrepresentation
of material fact and
(2) It is subject to the Internal Revenue Code
sections that expressly provided that effect be
given to their provisions notwithstanding any
other law or rule of law except Code section 7121.
By signing this agreement, the above parties certify
that they have read and agreed to its terms.
3. Settlement and Stipulated Decision for 1987
Respondent determined a deficiency in the joint tax of
Timothy Riffe, deceased, and Kathleen Pert, for tax year 1987.
Timothy Riffe, deceased, and Kathleen Pert petitioned the Tax
Court (Docket No. 15214-91), challenging respondent's
determination for that year. The parties settled that case.
This Court entered a stipulated decision on June 4, 1993, in
which Kathleen Pert, acting in her own behalf, and as personal
representative of the Estate of Timothy Riffe, agreed to a
deficiency in tax and additions to tax for 1987. Under the
settlement, the Estate of Timothy Riffe and Kathleen Pert agreed
to the same deficiency. Additions to tax for negligence and
substantial understatement of tax were imposed on Timothy Riffe,
deceased, but not on Kathleen Pert.
4. Notices of Transferee Liability
On May 27, 1994, respondent mailed two notices of transferee
liability to petitioner in which respondent determined: (a)
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Last modified: May 25, 2011