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ESTATE OF JONES v. C.I.R.

No. 84-1468.

795 F.2d 566 (1986)

ESTATE OF Ralph L. JONES, Deceased, Zepha H. Jones, Executrix, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided July 10, 1986.

Attorney(s) appearing for the Case

Alan C. Housholder (argued), Nashville, Tenn., Quentin L. Housholder, for petitioner-appellant.

Fred T. Goldberg, Jr., Chief Counsel, I.R.S., Washington, D.C., Glenn L. Archer, Jr., Michael L. Paup, Tax Div., Dept. of Justice, William S. Estabrook, Patricia A. Willing (argued), for respondent-appellee.

Before ENGEL and JONES, Circuit Judges and EDWARDS, Senior Circuit Judge.

ENGEL, Circuit Judge.

The Estate of Ralph L. Jones, Zepha H. Jones, Executrix (hereinafter "Taxpayer") appeals the decision of the Tax Court denying the enforcement of an alleged agreement entered into between the parties in March, 1983, settling the estate's federal estate tax liability. Taxpayer contends that the Tax Court was in error in holding either that there was not a valid settlement or that the settlement was based on a mutual mistake of fact. We affirm...

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