Raymond E. Sampson & Geneva Sampson v. Comm'r of Internal Revenue, 444 F.2d 530 (6th Cir. 1971). · Go Syfert
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Raymond E. Sampson & Geneva Sampson v. Comm'r of Internal Revenue, 444 F.2d 530 (6th Cir. 1971). Cases Citing This Book View Copy Cite
14 citation events across 3 distinct courts.
Strongest positive: Montgomery v. Commissioner
Top citers, strongest first. 6 distinct citers. How cited ↗
discussed Cited "see" Montgomery v. Commissioner (2×)
unknown court · 1975 · signal: see · confidence high
See Sampson v. Commissioner, 444 F. 2d 530 (6th Cir. 1971), affg. a Memorandum Opinion of this Court; Estate of Ella T.
discussed Cited "see, e.g." Renner v. Commissioner
Tax Ct. · 1994 · signal: see also · confidence low
Botany Worsted Mills v. United States , 278 U.S. 282 , 288 (1929) ; Estate of Meyer v. Commissioner , 58 T.C. 69 , 70 (1972) ; see also Sampson v. Commissioner , 444 F.2d 530 , 531 (6th Cir. 1971) , affg.
discussed Cited "see, e.g." Aberl v. United States (In Re Aberl)
Bankr. N.D. Ohio · 1993 · signal: see also · confidence low
See also Sampson v. Commissioner, 444 F.2d 530 (6th Cir.1971) (per curiam) (holding that informal agreement reached in meeting between taxpayer and representative of Appellate Division of the IRS in attempt to settle tax liability had no legal effect) (citations omitted); Joyce v. Gentsch, 141 F.2d 891 (6th Cir.1944) (holding that taxpayer was not precluded by an informal agreement from recovering any portion of the tax paid where the agreement did not comply with statutory requirements for a formal offer in compromise or closing agreement); c.f.
discussed Cited "see, e.g." ELLIS
unknown court · Joh · signal: see also · confidence low
See Botany Worsted Mills v. United States, 278 U.S. 282 , 288 (1929) ; Estate of Meyer v. Commissioner, 58 T.C. 69 , 70 (1972) ; see also Sampson v. Commissioner, 444 F.2d 530 , 531 (6th Cir. 1971) , affg.
discussed Cited "see, e.g." TUSSEY
unknown court · Joh · signal: see also · confidence low
See Botany Worsted Mills v. United States, 278 U.S. 282 , 288 (1929) ; Estate of Meyer v. Commissioner, 58 T.C. 69 , 70 (1972) ; see also Sampson v. Commissioner, 444 F.2d 530 , 531 (6th Cir. 1971) , affg. per curiam T.C.
cited Cited "see, e.g." Reynolds
unknown court · Joh · signal: see also · confidence low
Ed. 379 , 49 S. Ct. 129 (1929) ; Estate of Meyer v. Commissioner, 58 T.C. 69 , 70 (1972) ; see also Sampson v. Commissioner, 444 F.2d 530 , 531 (6th Cir. 1971) , affg.
Retrieving the full opinion text from the archive…
Raymond E. SAMPSON and Geneva Sampson, Petitioners-Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee
20942_1.
Court of Appeals for the Sixth Circuit.
Jun 30, 1971.
444 F.2d 530
Raymond E. Sampson in pro. per., Bruce I. Kogan, Atty., Dept, of Justice, Tax Div., Washington, D. C., for appellee; Johnnie M. Walters, Asst. Atty. Gen., Meyer Rothwacks, Gilbert E. Andrews, Attys., Tax Div., Dept, of Justice, Washington, D. C., on brief.
McCree, Brooks, Miller.
Cited by 14 opinions  |  Published
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.