Memorandum Findings of Fact and Opinion
JACOBS, Judge:
This matter is before the Court on petitioners' motion for partial judgment. Respondent determined a deficiency in petitioners' 1978 Federal income tax in the amount of $468,689. The sole issue for decision is whether respondent is bound by an alleged settlement agreement entered into with petitioner Bernhard F. Manko.
Unless otherwise indicated, all section references are to the Internal Revenue...
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