T.C. Memo. 2005-76
UNITED STATES TAX COURT
JOHANN KEIL AND CATHERINE KEIL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15206-02. Filed April 7, 2005.
In the summer of 2000, Ps, H and W, retained an
attorney, M, to represent them as to their 1993 and
1994 income taxes. W was M’s contact person for Ps,
and W specifically told M at the time of his retention
that he could not accept any settlement that affected
Ps without her consideration and approval of it. On
Dec. 9, 2003, M settled approximately 45 out of 50
issues in the case; M did not first seek or receive the
approval of either P. One day later, M signed and
caused to be filed with the Court a stipulation of
settled issues (first stipulation of settled issues)
that described the terms of this settlement. Neither P
was aware that M had settled these issues nor that he
had filed the first stipulation of settled issues, and
neither P authorized either of these acts. On or
before Dec. 14, 2003, M settled the remaining five
issues, without seeking or receiving the approval of
either P. After the latest settlement, M contacted W
to obtain her acceptance of both settlements without
telling her that he had already accepted them on behalf
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