122 T.C. No. 6
UNITED STATES TAX COURT
THOMAS E. JOHNSTON and THOMAS E. JOHNSTON, SUCCESSOR IN INTEREST
TO SHIRLEY L. JOHNSTON, DECEASED, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
THOMAS E. JOHNSTON, Petitioner v. COMMISSIONER OF INTERNAL
REVENUE, Respondent
Docket Nos. 26005-96, 2266-97. Filed February 11, 2004
Ps made a qualified offer, pursuant to sec. 7430,
I.R.C., to resolve Ps’ tax liabilities for the 1989,
1991, and 1992 tax years. R accepted Ps’ qualified
offer, without negotiation.
Thereafter, Ps sought to reduce the amounts stated
in the qualified offer by the amount of net operating
losses (NOLs) sustained in the 1988, 1990, 1993, and
1995 tax years. R refused to allow such a reduction,
claiming that R’s acceptance of Ps’ qualified offer
prevented Ps from reducing the agreed-upon amounts.
*This opinion supplements our opinion in Johnston v.
Commissioner, 119 T.C. 27 (2002).
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