United States v. Joel E. Cook

JONES, Circuit Judge:

The facts are not complex and are not in dispute. The question presented for decision is a narrow one. On July 6, 1962 a tax assessment was made by the United States against the appellant, Joel E. Cook. On February 24, 1965 Cook submitted to the Treasury Department an offer in compromise on a printed form furnished by the Internal Revenue Service. Included in the offer in compromise, and a part of the printed form, is the provision that,

“The undersigned proponent waives the benefit of any statute of limitations applicable to the assessment and/or collection of the…