- 4 - Respondent submitted to the Court a decision document (the Document) that she claims is in accordance with the Stipulation. By Order dated November 30, 1995, the Court directed petitioners to respond to the Document. Petitioners allege in their response that the 1984 self-employment tax shown in the Document is wrong. Petitioners allege in their response that their 1984 self-employment income equals the $41,857 of receipts shown in the Stipulation, less: (1) A $3,351 loss from Summit Equities, (2) a $31,562 loss from Diamond Leasing, and (3) a $2,567 loss from AIG Investors. Petitioners allege in their response that Gregory Summers “rendered substantial personal services“ to these three entities. Discussion The compromise and settlement of tax cases is governed by general principles of contract law. A settlement stipulation is in essence a contract. Each party agrees to concede some rights which he or she may assert against his or her adversary as consideration for those secured in the settlement agreement. Saigh v. Commissioner, 26 T.C. 171, 177 (1956). Like contracts, stipulations of settlement bind the parties thereto to the terms thereof. Stamos v. Commissioner, 87 T.C. 1451, 1455 (1986). In determining the proper meaning of the terms, we look to the language of the stipulation and the circumstances surrounding its execution. Robbins Tire & Rubber Co. v. Commissioner, 52 T.C. 420, 435-436 (1969); see also Brink v. Commissioner, 39 T.C. 602,Page: Previous 1 2 3 4 5 6 Next
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