MEMORANDUM OPINION
HOLMES, Judge:
In 2001, Richard Nichols and his wife Lisa reached a compromise with the IRS on their 1994 tax liability. The Nicholses agreed that the IRS could immediately assess and collect an agreed amount, but they reserved the right to sue for a refund. The Nicholses then learned that they had net operating losses from later years. They asked the Commissioner to let them use these losses to reduce their 1994 tax liability; they also...
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