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KORANGY v. C.I.R.

No. 89-2675.

893 F.2d 69 (1990)

Amile A. and Parvane S. KORANGY, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided January 2, 1990.

Attorney(s) appearing for the Case

John Hardin Young (Porter, Wright, Morris & Arthur; Michael A. Fracassi, Washington, D.C., on brief), for petitioners-appellants.

Michael James Roach (Shirley D. Peterson, Asst. Atty. Gen.; Gary R. Allen, Gilbert S. Rothenberg, Tax Div., U.S. Dept. of Justice, Washington, D.C., on brief), for respondent-appellee.

Before WILKINS, Circuit Judge, WINTER, Senior Circuit Judge, and MOTZ, District Judge for the District of Maryland, sitting by designation.

MOTZ, District Judge:

Amile and Parvane Korangy appeal from a decision of the Tax Court denying their motion to modify or vacate a Stipulation of Agreed Adjustments into which they entered with the government. In the stipulation the Korangys agreed that there was a deficiency in the amount of $270,415.00 in their personal income tax for the taxable year 1982. They now contend that they made an error in compiling a list which was used during the negotiations leading...

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