- 13 - principles of contract law are applied in construing such agreements. Robbins Tire & Rubber Co. v. Commissioner, 52 T.C. 420, 435-436 (1969); Fisher v. Commissioner, supra; Estate of Satin v. Commissioner, supra. Generally, we look within the "four corners" of the agreement to ascertain the intent of the parties. Rink v. Commissioner, 100 T.C. 319 (1993), affd. 47 F.3d 168 (6th Cir. 1995). Where an agreement is ambiguous, the Court may look to extrinsic evidence to determine the parties' intentions. Woods v. Commissioner, 92 T.C. 776 (1989). Consistent with basic principles of contract law, we begin our analysis with the plain language of the two piggyback agreements. The operative terms of the two piggyback agreements are virtually identical. Paragraph 2 of the 1985 piggyback agreement and paragraph 1 of the 1986 piggyback agreement state that all issues involving Kersting-related interest deductions will be redetermined on the same basis that the same tax shelter adjustments are resolved with respect to the tried cases. Equally important, paragraph 5 of the 1985 piggyback agreement and paragraph 4 of the 1986 piggyback agreement, which state that petitioners waive the restrictions on assessment and collection following entry of decisions in their cases, include the statement that any deficiencies in petitioners' cases will be "formulated by reference to the Tax Court's opinion." Based upon the plain meaning of the language of the piggyback agreements, we hold that the parties agreed to be bound by the Court'sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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