On June 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Howe v. Commissioner (T.C. Memo. 2020-78). The issues before the court in Howe were (1) whether the notice of deficiency is valid and (2) whether respondent is equitably estopped from denying the executed settlement agreement in Form 870-AD (Offer to Waive Restrictions on Assessment and Collection of Tax Deficiency and to Accept Overassessment).