Cole v. Commissioner

Second Circuit

Cole v. Commissioner

272 F.2d 13

Court of Appeals for the Second Circuit·Decided November 19, 1959·No. No. 16, Docket 25537·Published·Cited by 1 cases

Opinion

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.

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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.

Cole v. Commissioner, 272 F.2d 13 (2d Cir. 1959).

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Opinion

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