Boulez v. Commissioner
United States Tax Court
Respondent issued a deficiency notice in contravention of an assumed oral agreement between petitioner and respondent's Director of International Operations. Petitioner performed his obligations in reliance on said agreement.
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Respondent issued a deficiency notice in contravention of an assumed oral agreement between petitioner and respondent's Director of International Operations. Petitioner performed his obligations in reliance on said agreement. Held, the assumed oral agreement is not binding upon respondent, because (a) respondent's Director of International Operations did not have authority to enter into such agreement under sec. 7122, I.R.C. 1954, and the applicable regulations, revenue procedure, and delegation orders, and (b) respondent is not estopped from issuing the deficiency notice because of the…
1Opinion of the Court
OPINION
Tannenwald, Judge:
Respondent determined deficiencies in petitioner’s income tax in the amounts of $25,247.68 for the taxable year ended December 31, 1971, and $19,212 for the taxable year ended December 31,1972. The case is before us on petitioner’s motion for summary judgment but, as will subsequently appear, its posture is such that the Court may be in a position to enter a qualified decision for respondent (see note 2 infra).
Petitioner Pierre Boulez (Boulez), a French citizen, is a world-renowned conductor, composer, and music director. During 1971 and 1972, Boulez, then a resident…
2Cases cited28 opinions
- United States Ex Rel. Accardi v. ShaughnessySupreme Court of the United States · 1954
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Boske v. ComingoreSupreme Court of the United States · 1900
- Estate of Emerson v. CommissionerUnited States Tax Court · 1977
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3Cited by106 opinions
- Harold M. Reynolds v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1988
- Woods v. CommissionerUnited States Tax Court · 1989
- Pierre Boulez v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1987
- Kronish v. CommissionerUnited States Tax Court · 1988
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
101 more not listed; retrieve them via the Exa API.