Kelley v. Commissioner Internal Revenue Service

LEAVY, Circuit Judge: In these consolidated appeals we are called upon to determine whether the United States Tax Court (""Tax Court"") possesses the equitable power to reform consent-to-extend agreements entered into between taxpayers and the revenue collecting arm of the federal government. For the reasons which follow, we conclude that the Tax Court has a limited equitable power to reform such agreements, so long as they are properly before the Tax Court in the exercise of its subject matter jurisdiction.