GINELLA v. COMMISSIONER

Docket No. 24231-88.

62 T.C.M. 1554 (1991)

T.C. Memo. 1991-625

Thomas J. Ginella v. Commissioner.

United States Tax Court.

Filed December 17, 1991.


Attorney(s) appearing for the Case

Frank Bacon, for the petitioner. Ann M. Murphy, for the respondent.


Memorandum Opinion

TANNENWALD, Judge:

This case is before us on petitioner's motion for summary judgment which rests on the assertion that a binding settlement agreement exists between the parties. For the reasons, hereinafter set forth, we deny the motion.

This case has previously been before us in Ginella v. Commissioner [Dec. 47,052(M)], T.C. Memo. 1990-648, wherein we ruled that we were without jurisdiction...

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