Raymond E. Sampson and Geneva Sampson v. Commissioner of Internal Revenue

Sixth Circuit

Raymond E. Sampson and Geneva Sampson v. Commissioner of Internal Revenue

444 F.2d 530, 28 A.F.T.R.2d (RIA) 5109, 1971 U.S. App. LEXIS 9200

CourtCourt of Appeals for the Sixth Circuit

DecidedJune 30, 1971

Docket20942_1

StatusPublished

Cited by14 cases

This text of 444 F.2d 530 (Raymond E. Sampson and Geneva Sampson v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Raymond E. Sampson and Geneva Sampson v. Commissioner of Internal Revenue, 444 F.2d 530, 28 A.F.T.R.2d (RIA) 5109, 1971 U.S. App. LEXIS 9200 (6th Cir. 1971).

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Opinion

PER CURIAM.

This is an appeal prosecuted in pro se from a decision of the Tax Court, j[ 70,212 P-H Memo T.C. (1970), holding that taxpayers had failed to meet their burden of proving claimed medical expenses and charitable deductions and determining a deficiency in the amount of $152.70 for the 1967 tax year.

After disallowance of the deductions, the taxpayer husband met with a representative of the Appellate Division of the Internal Revenue Service in an attempt to settle his disputed tax liability. At this meeting an agreement was reached allowing all claimed deductions and taxpayer left the meeting with the understanding that a final settlement had been reached. However, the recommendations of the conferee of the Internal Revenue Service were rejected by his superiors and there were no further settlement negotiations.

Unfortunately, from the taxpayers’ standpoint, an informal agreement such as was reached in this case is not binding and has no legal effect. Botany Worsted Mills v. United States, 278 U.S. 282, 49 S.Ct. 129, 73 L.Ed. 379 (1929); Cleveland Trust Company v. United States, 421 F.2d 475 (6th Cir. 1970); Country Gas Service v. United States, 405 F.2d 147 (1st Cir. 1969).

From our review of the record and our consideration of the briefs and oral arguments of the parties, it is concluded that the decision of the Tax Court should be affirmed.

Affirmed.

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PER CURIAM.

This is an appeal prosecuted in pro se from a decision of the Tax Court, j[ 70,212 P-H Memo T.C. (1970), holding that taxpayers had failed to meet their burden of proving claimed medical expenses and charitable deductions and determining a deficiency in the amount of $152.70 for the 1967 tax year.

After disallowance of the deductions, the taxpayer husband met with a representative of the Appellate Division of the Internal Revenue Service in an attempt to settle his disputed tax liability. At this meeting an agreement was reached allowing all claimed deductions and taxpayer left the meeting with the understanding that a final settlement had been reached. However, the recommendations of the conferee of the Internal Revenue Service were rejected by his superiors and there were no further settlement negotiations.

Unfortunately, from the taxpayers’ standpoint, an informal agreement such as was reached in this case is not binding and has no legal effect. Botany Worsted Mills v. United States, 278 U.S. 282, 49 S.Ct. 129, 73 L.Ed. 379 (1929); Cleveland Trust Company v. United States, 421 F.2d 475 (6th Cir. 1970); Country Gas Service v. United States, 405 F.2d 147 (1st Cir. 1969).

From our review of the record and our consideration of the briefs and oral arguments of the parties, it is concluded that the decision of the Tax Court should be affirmed.

Affirmed.

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444 F.2d 530, 28 A.F.T.R.2d (RIA) 5109, 1971 U.S. App. LEXIS 9200, Counsel Stack Legal Research, https://law.counselstack.com/opinion/raymond-e-sampson-and-geneva-sampson-v-commissioner-of-internal-revenue-ca6-1971.

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