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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.
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