T.C. Memo. 1996-306
UNITED STATES TAX COURT
MAYER AND NINETTE STISKIN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 36140-86. Filed July 8, 1996.
In 1980, P became a limited partner in a tax
shelter limited partnership. In 1986, the Commissioner
issued a notice of deficiency for 1982 relating to
deductions claimed in connection with the limited
partnership, and Ps filed a petition in this Court. In
1988, 2 years after the case was docketed in this
Court, Ps signed a Form 906, "Closing Agreement on
Final Determination Covering Specific Matters."
Held: The closing agreement did not oust this
Court of jurisdiction.
Held, further, the closing agreement itself was in
any event void because signed on behalf of the IRS by
an Associate Chief of Appeals who did not have the
authority to enter into a closing agreement in a case
docketed in this Court. Delegation Order No. 97 (Rev.
19), 47 Fed. Reg. 19842 (May 7, 1982); Delegation Order
No. 225 (Rev. 1), 52 Fed. Reg. 13008 (Apr. 20, 1987).
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