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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