- 11 - under section 6621; and (4) execution of a closing agreement (Form 906) stating the settlement and resolving the entire matter for all years. Petitioners assert that the Plastics Recycling project settlement offer was extended to them, but they do not claim to have accepted the offer timely, so they effectively rejected it. In December 1988, the Miller cases were disposed of by settlement agreement between the taxpayers and respondent, and attorney Richard S. Kestenbaum executed the settlement on behalf of the Millers. This Court entered decision documents based upon those settlements on December 22, 1988. The settlement provided that the taxpayers in the Miller cases were liable for the addition to tax under the provisions of section 6659 for valuation overstatement, but not for the additions to tax under the provisions of sections 6661 and 6653(a). The increased interest under section 6621(c), premised solely upon Miller's interest in the recyclers for the taxable years at issue, was not applicable because Miller made payments prior to December 31, 1984, so no interest accrued after that time. Respondent did not notify petitioners or any other taxpayers of the disposition of the Miller cases. Estate of Satin v. Commissioner, T.C. Memo. 1994-435; Fisher v. Commissioner, T.C. Memo. 1994-434.8 8 Respondent attached copies of the Miller closing agreement and disclosure waiver to her objection to petitioners' motion for leave. Petitioners do not dispute the accuracy of the document (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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