- 4 - Barrister and a limited partnership that also was a party in Anderson Equip. Associates v. Commissioner, supra. Our opinion in Chimblo v. Commissioner, supra, was filed in December of 1997. Therein, we sustained respondent’s imposition of sections 6653(a)(1), (a)(2), and 6661 additions to tax. On March 16, 1998, in the instant case, petitioners and respondent entered into a settlement stipulation, referred to by the parties as a piggyback agreement, which provided that all of the issues in the instant case would be resolved on the same basis as those issues are finally resolved in Chimblo v. Commissioner, supra. The stipulation specifically stated as follows: All of the remaining issues in this case shall be resolved on the same basis and by application of the same formula as that which resolves the like issues in the case in this Court of Catherine Chimblo and Estate of Gus Chimblo, Deceased, Catherine Chimblo, Executrix, Docket No. 16546-96 (hereafter the CONTROLLING CASE), as if Petitioners in this case were the same as the taxpayers in the CONTROLLING CASE. If an issue in the CONTROLLING CASE is appealed, the final decision, whether on appeal or on remand, shall be binding on the like issue in this case. In a number of motions for continuance of scheduled trial dates (filed subsequently to the above March 16, 1998, settlement stipulation), the parties herein represented to the Court that all of the disputed issues in this case would be resolved on thePage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011