14
notices of deficiency dated December 4, 1992, were issued prior
to the expiration of the period of limitations. We agree with
respondent.
General contract law principles govern tax case settlements.
Robbins Tire & Rubber Co. v. Commissioner, 52 T.C. 420, 435-436,
supplemented by 53 T.C. 275 (1969); Smith v. Commissioner, T.C.
Memo. 1991-412. Where the intent of the parties to settle is
evident and the terms of the settlement are otherwise
ascertainable, then a tax settlement agreement may be binding
even if it consists only of letters of offer and acceptance.
Treaty Pines Invs. Partnership v. Commissioner, 967 F.2d 206, 211
(5th Cir. 1992); Haiduk v. Commissioner, T.C. Memo. 1990-506.
Petitioners argue that the Form 870-L(AD) is ambiguous as to
which party is making an offer and which party is accepting the
offer. Respondent argues that the Form 870-L(AD) is not
ambiguous and that it constitutes the settlement agreement
between the parties. Contract law principles generally direct
that we look within the "four corners" of the agreement, unless
it is ambiguous as to essential terms. Rink v. Commissioner, 100
T.C. 319, 325 (1993), affd. 47 F.3d 168 (6th Cir. 1995).
Petitioners contend that the Form 870-L(AD) is ambiguous in
that it sets forth two offers: (1) An offer to enter into a
settlement agreement, and (2) an offer to waive the restrictions
on the assessment and collection of any deficiency. Petitioners
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