Cole v. Commissioner
This text of 272 F.2d 13 (Cole v. Commissioner) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
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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Cite This Page — Counsel Stack
272 F.2d 13, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cole-v-commissioner-ca2-1959.