- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011