United States v. Cooper-Smith

BARTELS, District Judge.

This action involves the interpretation of a waiver of statute of limitations provision contained in a printed Offer in Compromise of a federal tax liability.

To reduce to judgment assessments for the years 1945 to 1947, inclusive, for federal income taxes, civil fraud penalties and interest, totalling $56,138.79, pursuant to a decision of the Tax Court of the United States entered on December 23, 1959, the Government filed a complaint against the defendant. It now moves for a summary judgment against the defendant and the defendant cross-moves for a summary judgment…