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.
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