- 2 -
Held: There was no mutual mistake or
misrepresentation sufficient to cause the offer in
compromise to be set aside. P’s equitable estoppel
argument is not considered because it was not timely
raised.
John R. McCabe, for petitioner.
Patrick W. Lucas, for respondent.
OPINION
GOEKE, Judge: This matter is before the Court on the issue
of whether petitioner is barred from seeking relief from joint
and several liability under former section 6013(e)1 and section
6015 for the years 1986 and 1987 because he entered into an offer
in compromise with respondent for those years. We hold that the
offer in compromise is valid and petitioner is barred from
seeking relief from joint and several liability.
Background
The parties submitted the issue fully stipulated. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference. Petitioner’s mailing address was in
Yorba Linda, California, at the time he filed his petition.
1Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended. Dollar amounts are
rounded.
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