Hunt v. Commissioner

HUTCHESON, Circuit Judge.

This is the second time that this proceeding to fix petitioner’s liability as transferee of Burkburnett Refining Company has been here.1 It was here before on the Commissioner’s petition to review the ruling of the Board that the collection of the tax was barred. This ruling was based on its finding that a limitation waiver Hunt had executed as president of the company, more than three years after its dissolution, was ineffective to bind the company. We held that Hunt was estopped to set up his lack of authority and to dispute the binding effect of the waiver. We…