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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's
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