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Held: The parties entered into a contract to
settle the docketed cases, as evidenced by Ps’
qualified offer and R’s acceptance of that offer.
Held, further, Ps are not now allowed to reduce
the amounts stated in the qualified offer for the years
at issue by the amount of NOLs sustained in the 1988,
1990, 1993, and 1995 tax years.
Lorraine G. Howell and Kenneth M. Barish, for petitioners.
Nicholas J. Richards and Kevin W. Coy, for respondent.
SUPPLEMENTAL OPINION
NIMS, Judge: Respondent determined the following
deficiencies and penalties with respect to petitioners’ Federal
income taxes:
Penalties
Petitioner Year Deficiency Sec. 6662(a) Sec. 6663
Thomas E. Johnston and *1989 $1,546,160 $309,232 $1,159,620
* * Shirley L. Johnston,
Deceased
Docket No. 26005-96
Thomas E. Johnston 1991 289,396 -- 217,047
Docket No. 2266-97 1992 341,908 -- 256,431
By answer respondent also asserted increased deficiencies and
penalties in docket Nos. 26005-96 and 2266-97.
These consolidated cases are presently before the Court on
respondent’s motion for summary judgment filed on September 2,
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Last modified: May 25, 2011