Richard Nichols and Lisa Nichols - Page 1

                                  T.C. Memo. 2007-5                                   

                               UNITED STATES TAX COURT                                

                  RICHARD NICHOLS AND LISA NICHOLS, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 1384-05L.              Filed January 9, 2007.               

               David B. Shiner, for petitioners.                                      
               Gregory J. Stull, for respondent.                                      

                                 MEMORANDUM OPINION                                   

               HOLMES, Judge: In 2001, Richard Nichols and his wife Lisa              
          reached a compromise with the IRS on their 1994 tax liability.              
          The Nicholses agreed that the IRS could immediately assess and              
          collect an agreed amount, but they reserved the right to sue for            
          a refund.  The Nicholses then learned that they had net operating           
          losses from later years.  They asked the Commissioner to let them           
          use these losses to reduce their 1994 tax liability; they also              

Page:   1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011