- 7 - In Dorchester Indus. Inc. v. Commissioner, 108 T.C. at 330, we stated, quoting Manko v. Commissioner, T.C. Memo. 1995-10, that: For almost a century, it has been settled that voluntary settlement of civil controversies is in high judicial favor. Williams v. First Natl. Bank, 216 U.S. 582, 595 (1910); St. Louis Mining & Milling Co. v. Montana Mining Co., 171 U.S. 650, 656 (1898). A valid settlement, once reached, cannot be repudiated by either party, and after the parties have entered into a binding settlement agreement, the actual merits of the settled controversy are without consequence. This Court has declined to set aside a settlement duly executed by the parties and filed with the Court in the absence of fraud or mutual mistake. Stamm Intl. Corp. v. Commissioner, 90 T.C. 315 (1988); Spector v. Commissioner, 42 T.C. 110 (1964). However, a court will not force a settlement on parties where no settlement was intended. Autera v. Robinson, 419 F.2d 1197 (D.C. Cir. 1969). When we examine the language used and the surrounding circumstances, we see that the stipulations of settled issues in Betsy’s dockets are styled “Betsy S. Grossman, Petitioner” and show the docket numbers of Betsy’s dockets in the headings; they do not show petitioner’s name or the docket numbers of his cases in their headings. Although Betsy’s petitions result from joint notices of deficiency, Betsy’s dockets deal only with Betsy’s deficiencies and not with petitioner’s deficiencies. The stipulations of settled issues in Betsy’s dockets purport to be agreements between the parties in those dockets; petitioner is not and never was a party in those dockets. In the context of the foregoing, the simplest and most direct interpretation of Betsy’s and the Commissioner’sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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