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).Page: 1 2 3 4 5 6 7 8 9 10 Next
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