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The taxpayer’s [sic] qualified offer is as follows
according to the case docket number and tax years
involved:
Docket No. Tax Year Amount of Qualified Offer
26005-96 1989 $ 35,000
2266-97 1991, 1992 $ 70,000
$105,000
This $105,000 offer is made as a qualified offer
for purposes of IRC �7430(g). Therefore, in making the
offer, the taxpayer is aware that his offer is to
resolve all adjustments in the court proceeding. Such
offer will fully resolve the taxpayer’s [sic] liability
as to those adjustments.
By letter dated February 10, 2003, respondent accepted
petitioners’ qualified offer, without negotiation.
After respondent accepted petitioners’ qualified offer,
petitioners raised with respondent the issue of reducing the
agreed-upon amounts by applying NOLs from the 1988, 1990, 1993,
and 1995 tax years.
On February 14, 2003, the Court held a conference call with
counsel for the parties. Counsel for the parties informed the
Court that the parties had reached a basis for settlement and
that there remained the issue of whether petitioners are allowed
to reduce the agreed-upon amounts for the 1989, 1991, and 1992
tax years by applying NOLs from the 1988, 1990, 1993, and 1995
tax years.
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