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PERT v. COMMISSIONER

Docket Nos. 13783-94, 13784-94.

105 T.C. 370 (1995)

HARVEY M. PERT, TRANSFEREE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT KATHLEEN M. PERT, F.K.A. KATHLEEN M. RIFFE, TRANSFEREE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 15, 1995.

Attorney(s) appearing for the Case

B. Gray Gibbs, for petitioners.

Michael A. Pesavento, for respondent.

OPINION

COLVIN, Judge:

This case is before the Court on respondent's motion for partial summary judgment on two issues:

(1) Whether petitioner Harvey Pert may contest (on grounds other than fraud, malfeasance, or misrepresentation of a material fact) the tax liability established by closing agreements for 1986, 1988, and 1989 under section 7121 which were agreed to: (a) By Kathleen Pert, and (b) by Kathleen Pert, personal representative of...

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