- 5 -
have been what the parties intended, but we cannot rewrite the
Separation Agreement. While we may be sympathetic with
petitioner’s position, this Court also cannot rewrite statutes
enacted by Congress in order to reach what may be perceived as a
more equitable result. See Commissioner v. Gooch Milling &
Elevator Co., 320 U.S. 418 (1943). Respondent is sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011