Richard E. Warner and Virginia A. Warner v. Commissioner of Internal Revenue

OPINION

SNEED, Circuit Judge:

This case demonstrates that the bureaucratic way in which the Commissioner must gather revenue leaves little opportunity for ad hoc face-to-face adjustments that sometimes are made between individual debtors and creditors.

The appellants’ 1969 federal income tax return omitted certain items of income which, in fact, were reflected on proper W — 2 forms that were attached to the return. The return showed appellants entitled to a refund of $2,070.15. After a false start in which an “incorrect” refund check in the amount of $20.70 was returned by the appellants, the…