Thomas E. Johnston and Thomas E. Johnston, Successor in Interest to Shirley L. Johnston, Deceased - Page 1

                                   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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