El Charro TV Rental, Inc., Diana L. Peters, Tax Matters Person - Page 2

                                        - 2 -                                         

          City, Oklahoma, and was tried on June 1, 1994.  At the conclusion           
          of the trial, the parties agreed to defer the setting of post-              
          trial briefing dates in order to await the outcome of the earlier           
          case1 already under consideration by another division of this               
          Court.  The parties in this case stipulated to a substantial                
          portion of the facts and proffered only a limited amount of                 
          testimony.  The parties believed that they could agree to be                
          bound by the outcome of El Charro I, but presented their evidence           
          in the event that factual distinctions were found in that case.             
          The earlier case involves three cases that had been consolidated            
          for trial.  El Charro TV Rental, Inc. (El Charro), is one of the            
          participating entities involved in the earlier consolidated                 
          cases.  Petitioner’s 2 taxable years prior to those before the              
          Court in this case are the subject of El Charro I.  It was                  
          thought that an opinion in El Charro I could obviate the need for           
          briefing and an opinion in this case.                                       
               Following an opinion in El Charro I, the parties contacted             
          the Court and advised that an agreement had been reached to                 
          settle all issues in this case subject to the outcome of                    
          petitioner's appeal of El Charro I.  On June 15, 1995, the                  

          1 For purposes of this opinion, the earlier case is referred                
          to as "El Charro I".  ABC Rentals of San Antonio, Inc. v.                   
          Commissioner, T.C. Memo. 1994-601, affd. without published                  
          opinion sub nom. El Charro TV Rental, Inc. v. Commissioner, 79              
          F.3d 1145 (5th Cir. 1996), and revd. and remanded 97 F.3d 392               
          (10th Cir. 1996).                                                           

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011