General Split Corporation, a Wisconsin Corporation v. United States
Court of Appeals for the Seventh Circuit
1Opinion of the Court
SPRECHER, Circuit Judge.
This case presents the question of whether a settlement agreement, effected by, inter alia, the execution of a Form 870-AD equitably estopped the taxpayer from later seeking a refund of deficiencies paid as part of the settlement.
I
Commencing with its organization in 1955, the taxpayer entered into a loan agreement with Kivie Kaplan (Kaplan Loan) providing for a loan of $175,000 to be repaid with interest within ten years. In 1959, taxpayer entered into a loan agreement with the Levine and So-kol family trusts (trust loans) providing . for a $50,000 loan to be repaid…
2Cases cited9 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Bessie Lasky and Jesse L. Lasky v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
- Raleigh & Gaston Railroad v. ReidSupreme Court of the United States · 1872
- Scott v. FordOregon Supreme Court · 1908
- Dimitrious J. Lignos and Evelyn Lignos v. United StatesCourt of Appeals for the Second Circuit · 1971
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3Cited by11 opinions
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- Arthur L. Stair and Bernice Stair v. United StatesCourt of Appeals for the Second Circuit · 1975
- William Whitney and Barbara Whitney v. United StatesCourt of Appeals for the Ninth Circuit · 1987
- McGraw-Hill, Inc. v. United StatesUnited States Court of Claims · 1980
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