Morris Moskowitz v. United States

*452DURFEE, Judge.

The plaintiff, an individual taxpayer, seeks to recover the difference between income taxes, interest, and penalties for the calendar years 1941, 1942, and 1948 paid under a deficiency assessment and an amount claimed to be an offer of settlement accepted by the Collector of Internal Revenue. Briefly stated, the facts are these: following an examination of plaintiff’s income tax returns for 1941, 1942, and 1943, by the Bureau of Internal Revenue, he was informed, because of his failure to report certain items of income, of proposed additional taxes and penalties in excess of…