Vincent and Clotilde Farrell, Jr. - Page 16

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          Goldman v. Commissioner, 39 F.3d 402 (2d Cir. 1994), affg. T.C.             
          Memo. 1993-480.  Absent wrongful, misleading conduct or mutual              
          mistake, we enforce a stipulation of settlement in accordance               
          with our interpretation of its written terms.  Stamm Intl. Corp.            
          v. Commissioner, 90 T.C. 315 (1988); Scherr v. Commissioner, T.C.           
          Memo. 1990-225.  Where the language of an agreement is                      
          unambiguous, we look within the "four corners" of the instrument            
          to ascertain the intent of the parties.  Goldman v. Commissioner,           
          supra; see Estate of Satin v. Commissioner, T.C. Memo. 1994-435,            
          and Fisher v. Commissioner, T.C. Memo. 1994-434, and cases cited            
          therein.                                                                    
               Petitioners first assert that the piggyback agreement                  
          designates both of the Miller cases as test cases, instead of               
          just one, so as to extend the scope of the agreement to the years           
          at issue in those cases, such as 1982.  In the Estate of Satin              
          and Fisher cases, we found that the piggyback agreement entitled            
          participant taxpayers to elect to accept the results of the                 
          Miller cases or the Provizer case.  There is no language in the             
          agreement extending the result of the controlling cases to any or           
          all cases of the participant taxpayers, not referenced in the               
          agreement, simply because they concern the same years addressed             
          in the controlling cases.  Petitioners' theory as to why both               
          Miller cases were designated controlling cases is speculation               
          unsupported by the terms of the piggyback agreement.                        






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