- 6 - * * * * * * * TABLE 1 (In pertinent part) TOTAL ORDINARY SHORT TERM LONG TERM YEAR ALLOWED GAIN (LOSS) GAIN (LOSS) 1980 (21,822) 22,966 3,104 After the parties executed the Closing Agreement, respondent mailed to petitioners a proposed Decision and overpayment Stipulation, together with the revised Computations. Respondent, by letter, twice asked petitioners to execute and return the proposed Decision and overpayment Stipulation. Petitioners did not sign the proposed Decision and overpayment Stipulation. Nearly 2 years after the Computations had last been revised by the parties, petitioner advised respondent by letter that he believed the proposed Decision document and related Computations did not accurately reflect the terms of the Closing Agreement and consequently were unacceptable. In essence, petitioner claimed for the first time that the Closing Agreement did not mandate inclusion of the guaranteed payment petitioner actually received in 1980. Section 7121(a) authorizes respondent to enter into an agreement in writing with any person relating to the liability of such person in respect of any internal revenue tax for any taxable period. A Closing Agreement is binding on the parties as to the matters agreed upon and may not be annulled, modified, set aside, or disregarded in any suit, action, or proceeding, exceptPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011