Cole v. Commissioner

U.S. Court of Appeals for the Second Circuit
Cole v. Commissioner, 272 F.2d 13 (2d Cir. 1959)

Cole v. Commissioner

Opinion of the Court

PER CURIAM.

The only ground assigned for review is that the Tax Court refused to enter orders of deficiency limited to the amounts stated in a stipulation prepared on behalf of the Commissioner during negotiations for settlement, signed by the taxpayer, but never signed or finally agreed to by the Commissioner. Under the circumstances we cannot see how the Commissioner may be limited in his recovery of deficiencies or estopped to claim them.

The decision of the Tax Court is affirmed.

Reference

Full Case Name
Frank COLE, alias Frank Shapiro v. COMMISSIONER OF INTERNAL REVENUE
Cited By
1 case
Status
Published