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).Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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