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Recycling project as well as the increased rate of interest under
section 6621(c). Issues concerning the additions to tax under
sections 6659 and 6653(a)(1) and (2) were not resolved.
On August 25, 1994, this Court filed opinions in two
Plastics Recycling cases: Estate of Satin v. Commissioner, supra
and Fisher v. Commissioner, supra. At issue in the Estate of
Satin and Fisher cases were two piggyback agreements virtually
identical to the one executed by petitioners and respondent for
docket No. 1173-88. Noting that the cases involved "peculiar, if
not unique circumstances", this Court held that the piggyback
agreements entitled the taxpayers to the same settlement as had
been reached in the Miller cases. Docket No. 1173-88 has
subsequently been settled pursuant to the piggyback agreement.
Respondent represents that administrative settlements have been
made with taxpayers in each of the relatively few cases, like
docket No. 1173-88, in which the taxpayer executed a piggyback
agreement like those discussed in Estate of Satin v.
Commissioner, supra, and Fisher v. Commissioner, supra.
3. Discussion
The motion for entry of decision here under consideration
raises the principle of equal treatment of similarly situated
taxpayers, the interpretation of a Stipulation of Settlement
entered into by petitioners and respondent in a separate case
(docket No. 1173-88), and equitable estoppel. In effect,
petitioners seek to resurrect the settlement offer they rejected.
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