William T. and Nicole L. Gladden - Page 1

                                   120 T.C. No. 16                                    

                               UNITED STATES TAX COURT                                

                WILLIAM T. GLADDEN AND NICOLE L. GLADDEN, Petitioners                 
                  v. COMMISSIONER OF INTERNAL REVENUE, Respondent*                    

               Docket No. 16932-97.             Filed June 27, 2003.                  

                    Held:  Where petitioners made a “qualified offer”                 
               under sec. 7430(c)(4)(E), I.R.C., on a substantive tax                 
               adjustment and thereafter litigation occurred and court                
               determinations were made on arguments or issues                        
               relating to the substantive tax adjustment and where                   
               the parties ultimately entered into a settlement of the                
               substantive tax adjustment, the “settlement limitation”                
               on qualified offers that is set forth in sec.                          
               7430(c)(4)(E)(ii)(I), I.R.C., is not applicable.                       

               William L. Raby, for petitioners.                                      
               Rachael J. Zepeda, for respondent.                                     

          *    This Opinion supplements Gladden v. Commissioner, 112 T.C.             
          209 (1999), revd. and remanded 262 F.3d 851 (9th Cir. 2001).                

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