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April 5, 2006, objected, and the parties presented their views in
documents, the last of which was filed July 3, 2006. The
question presented by the parties’ controversy is whether
petitioners and respondent entered into an enforceable agreement
to settle any part of this case.
Background
Respondent’s examination in this case focused upon whether
petitioners were entitled to certain contribution deductions that
they claimed on their Federal tax return. In the notice of
deficiency, respondent determined that petitioners were not
entitled to deductions for cash contributions claimed on their
2002 joint Federal income tax return. This case was being
handled in Omaha, Nebraska (Omaha case). The examination in the
Omaha case involved only the substantiation of cash contribution
deductions. Respondent had examined earlier taxable years of
petitioners, and in those cases the deductibility of noncash
contributions was in controversy. Respondent’s counsel in the
Omaha case was Henry N. Carriger. At the time of the events we
consider here, petitioners’ earlier tax years that had already
been petitioned to this Court were scheduled for trial in
Phoenix, Arizona, and were being handled by a different counsel
for respondent, Anne W. Durning (Phoenix cases).
On June 28, 2005, petitioners’ petition in the Omaha case
was filed, and their representatives thereafter began working
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