- 28 - section 7121 because there was a binding settlement agreement in the instant case. We did not come away from this part of the case with the belief that we understand substantially everything that happened. We do not understand how it came to be that petitioners’ letter to the Secretary of the Treasury elicited the response that there was a binding settlement agreement. We have recently discussed the nature of, and requirements for, binding settlement agreements. Dorchester Industries, Inc. v. Commissioner, 108 T.C. 320 (1997). We have reexamined the record in the instant case; we conclude, and we have found, that petitioners and respondent did not have a binding settlement agreement, nor did they enter into a section 7121 agreement with respect to the instant case or any issue therein. Respondent’s significant concessions, whether by stipulation or unilateral, are limited as described supra note 2. Those concessions will be given effect in the Rule 155 computation, but do not have the far-reaching effect that petitioners seek. Because we conclude that there was not a settlement agreement in the instant case, we do not need to consider, and we do not consider, whether any individuals with whom petitioners dealt had authority to enter into settlement agreements on behalf of respondent. We hold for respondent on this issue.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
Last modified: May 25, 2011