Legal Opinion
United States v. Lane
Court of Appeals for the Fifth Circuit
Decided May 9, 1962No. Nos. 19142, 19143PublishedCited by 57 opinions
1Opinion of the Court
TUTTLE, Chief Judge.
The primary issue on this appeal is whether the Government can revive the original income tax liability of a taxpayer who has breached a compromise agreement covering the liability. The District Court resolved this question adversely to the Government. We reverse.
The facts giving rise to this controversy are undisputed. During 1954 and 1955, the taxpayer, Robert C. Lane,1 made offers to representatives of the Commissioner of Internal Revenue in compromise of his outstanding income tax liability for the years 1947, 1948, 1949, 1952 and 1953. The indebtedness, amounting to…
2Cases cited2 opinions
- Jacksonville Terminal Company v. Railway Express Agency, IncorporatedCourt of Appeals for the Fifth Circuit · 1962
- Walker v. Alamo Foods Co.Court of Appeals for the Fifth Circuit · 1927
3Cited by57 opinions
- James M. Robinette v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Eighth Circuit · 2006
- Robinette v. Comm'rUnited States Tax Court · 2004
- Sarmiento v. United StatesCourt of Appeals for the Second Circuit · 2012
- Maniolos v. United StatesDistrict Court, S.D. New York · 2010
- William L. Smith and Jacquelyn Smith v. United StatesCourt of Appeals for the Fifth Circuit · 1988
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