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Co., submitted a protest letter (protest letter) to respondent on
behalf of SAB Management. The protest letter included the
following statement:
We hereby agree to follow the Tax Court’s decision in
the lead cases selected in accordance with the Order of
June 12, 1987, such cases being:
1. Elliot I. Miller, Petitioner
v. Commissioner of Internal Revenue, Respondent,
Docket No. 10382-86
2. Elliot I. Miller and Myra K. Miller, Petitioner
Commissioner of Internal Revenue, Respondent,
Docket No. 10383-86
3. *Leo Fine and Judith H. Fine, Petitioners
v. Commissioner of Internal Revenue, Respondent,
Docket No. 35437-85
* * * * * * *
* New controlling case:
Harold M. Provizer and Joan Provizer, Petitioners
v. Commissioner of Internal Revenue, Respondent,
Docket No. 27141-86.
On January 20, 1989, on behalf of SAB Foam, Becker
submitted the following notice to respondent:
In our protest dated September 28, 1988, we stated
that the Partnership agreed to be bound by the lead
cases (Fine, Miller and Miller).
Due to various changes in circumstances including
but not limited to a settlement of all such then
pending lead cases, the Partnership hereby withdraws
its statement to be bound by such cases or any other
case.
Becker mailed this notice by certified mail, return receipt
requested, and signed it “Stuart Becker, Tax Matters Partner”.
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