Rountree v. Commissioner
United States Tax Court
On May 30, 1966, the petitioner filed an amended income tax return for the taxable year, 1965, in which he calculated that he owed $45.55 in additional income taxes for that year. The respondent, in accepting the petitioner's check for $45.55, did not agree to release the petitioner from further tax liability.
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On May 30, 1966, the petitioner filed an amended income tax return for the taxable year, 1965, in which he calculated that he owed $45.55 in additional income taxes for that year. The respondent, in accepting the petitioner's check for $45.55, did not agree to release the petitioner from further tax liability. Held, the respondent was not bound contractually as to the amount of the petitioner's income tax liability for the year 1965 and was not estopped from issuing a statutory notice of deficiency for that year. The petitioner failed to establish that, during the year 1965, he provided over…
1Opinion of the Court
Brooks W. Rountree v. Commissioner.
Rountree v. Commissioner
Docket No. 3377-69.
United States Tax Court
T.C. Memo 1971-32; 1971 Tax Ct. Memo LEXIS 300; 30 T.C.M. (CCH) 137; T.C.M. (RIA) 71032;
February 18, 1971, Filed.
On May 30, 1966, the petitioner filed an amended income tax return for the taxable year, 1965, in which he calculated that he owed $45.55 in additional income taxes for that year. The respondent, in accepting the petitioner's check for $45.55, did not agree to release the petitioner from further tax liability. Held, the respondent was not bound contractually as to the amount of the…
2Cases cited7 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Stafford v. CommissionerUnited States Tax Court · 1966
- Fitzner v. CommissionerUnited States Tax Court · 1959
- Brown v. CommissionerUnited States Tax Court · 1967
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Brooks W. Rountree v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1972