RAYMOND E. SAMPSON AND GENEVA SAMPSON, PETITIONERS-APPELLANTS,
v.
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE
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The court held that an informal agreement with an IRS representative is not binding and does not have legal effect.
Taxpayers claimed medical and charitable deductions, which were disallowed. The taxpayer believed a settlement was reached with an IRS representative,…
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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.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Botany Worsted Mills v. United States, 278 U.S. 282 (U.S. 1929)
- The Cleveland Tr. Co. & A. Dean Perry v. United States, 421 F.2d 475 (6th Cir. 1970)
- Country GAS Serv., Inc. v. United States, 405 F.2d 147 (1st Cir. 1969)