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STAMM INTERNATIONAL CORP. v. COMMISSIONER

Docket Nos 2690-84, 5543-84, 8225-86.

90 T.C. 315 (1988)

STAMM INTERNATIONAL CORP., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 22, 1988.

Attorney(s) appearing for the Case

E.A. Dominianni, Michael J. Calvey, and Paula Silberthau, for the petitioner.

Richard J. Sapinski, Eugene J. Wien, and Lisa Primavera-Femia, for the respondent.

OPINION

COHEN, Judge:

Respondent has filed a motion to withdraw memorandum of settlement and recalendar for trial, seeking to avoid the provisions of a memorandum of settlement filed November 25, 1986. Respondent contends that the agreed settlement was intended to be a "bottom line" settlement in which petitioner would pay between $1.8 million and $1.9 million. Petitioner contends that the settlement was on...

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