- 19 - Gulfstream Land & Dev. Corp. & Subs. v. Commissioner, 71 T.C. 587, 596 (1979). Summary judgment is intended to expedite litigation and avoid unnecessary and expensive trials. Florida Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988). We discussed in Manko I the nature of, and requirements for, binding settlement agreements. Essentially, the compromise and settlement of tax cases is governed by general principles of contract law. Dorchester Indus., Inc. v. Commissioner, 108 T.C. 320, 330 (1997). A. Scope of the Settlement Agreement The evidence clearly establishes that there was one blanket settlement between respondent and petitioners (that respondent offered to all Arbitrage Management investors in December 1987) encompassing all years (both docketed and nondocketed) in which petitioners claimed Arbitrage Management partnership loss deductions. It was a package settlement. The settlement resolved an issue (i.e, the deductibility of Arbitrage Management losses) rather than a specific taxable year. Moreover, the offer was available to petitioners, who were members of a class to whom the offer was extended, on the same terms that were available to all other Arbitrage Management investors. Petitioners accepted the blanket settlement offer referred to in Ms. Kaplan's January 15, 1988, acceptance letter. That letter clearly stated that thePage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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