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JOHNSTON v. C.I.R.

No. 04-73833.

461 F.3d 1162 (2006)

Thomas E. JOHNSTON, and Thomas E. Johnston, Successor In Interest To Shirley L. Johnston, Deceased, Petitioner-Appellant, v. COMMISSIONER of INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed September 1, 2006.

Attorney(s) appearing for the Case

Lorraine Howell, Costa Mesa, CA, and Kenneth M. Barish, Beverly Hills, CA, for appellant Thomas E. Johnston.

Thomas J. Clark and Karen D. Utiger, Washington, D.C., for appellee Commissioner of Internal Revenue.

Before: D.W. NELSON, RAWLINSON, and BEA, Circuit Judges.

BEA, Circuit Judge:

This case presents an attempt at "post-deal negotiation." It doesn't usually work in business. Why should we treat the tax collector differently?

Specifically, we address the following question: when a taxpayer offers to pay the Internal Revenue Service a sum certain to "fully resolve all adjustments at issue" for certain tax years, and the Commissioner accepts his offer, may the taxpayer then apply net operating losses ("NOLs") to reduce...

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