T.C. Memo. 2004-58 UNITED STATES TAX COURT BECKER HOLDING CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6400-03. Filed March 10, 2004. Jerald David August and James P. Dawson, for petitioner. Andrew M. Tiktin and Sergio Garcia-Pages, for respondent. MEMORANDUM OPINION HAINES, Judge: The matter is before the Court on the parties’ cross-motions for partial summary judgment pursuant to Rule 121.1 The issues to be decided are: (1) Whether the parties agreed to a settlement with respect to petitioner’s tax 1 Unless otherwise indicated, Rule references are to the Tax Court Rules of Practice and Procedure, and section references are to the Internal Revenue Code, as amended.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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