T.C. Memo. 1996-17
UNITED STATES TAX COURT
GREGORY SUMMERS AND JUSTINE SUMMERS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16175-93. Filed January 22, 1996.
Before trial, the parties negotiated a settlement
specifying the manner of resolving this case. Ps now
seek to raise an issue as to the amount of income
subject to self-employment tax. This issue was not
raised or preserved by Ps in the pleadings or the
stipulated settlement agreement. Held: The issue
raised by Ps is a new issue that is not before the
Court.
Michael Weitzner, for petitioners.
James B. Biagi, for respondent.
MEMORANDUM OPINION
LARO, Judge: This matter is before the Court on
respondent’s motion for entry of decision in accordance with a
stipulation of settlement (the Stipulation) filed June 13, 1994.
We must decide whether the subject decision should reflect less
self-employment tax than determined by respondent. We hold that
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