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totaling $130,836 in December of 1988, petitioners filed two sets
of claims for refund therefor -- the first in 1990 and the second
in 1994. The filing by petitioners of the claims for refund in
1990 and 1994 is inconsistent with and disproves petitioners’
contention that they had settled the related tax liabilities in
December of 1988.
The total amount of petitioners’ December 27, 1988, payments
(and the amount of the various separate checks designated for
taxes and interest), with one exception for 1 year, do not match
the calculations of what would have been due under any of
respondent’s settlement offers. Further, in context, the
April 26, 1995, letter from respondent’s Appeals officer clearly
did not constitute an offer or acceptance of any settlement
agreement.
Petitioners’ various alternative arguments (e.g., that
petitioners’ December 27, 1988, payments and respondent’s receipt
thereof should be treated as an accord and satisfaction of the
tax liabilities then asserted against petitioners relating to
White Rim and/or to Syn-Fuel, or that petitioners’ investments in
Syn-Fuel should be treated as giving rise to loss deductions for
fraud) are rejected. No credible evidence supports petitioners’
alternative arguments. Other arguments made by petitioners that
are not specifically addressed herein have been considered and
are rejected.
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