King David and Virginia C. David v. Sheldon Cohen

Appellants, King David and his wife, Virginia C. David, were indebted to the United States for income taxes for the years 1960 through 1962. On January 14, 1966, Mr. David met with appellee Jane Brown, a receptionist in the Washington, D. C., office of the Internal Revenue Service, who referred him to appellee Gladys Armwood, a tax examiner in that office. The purpose of the meeting was to discuss the possibility of satisfying appellants’ tax liabilities by deferred payments. The procedure for making installment payments was explained, but nothing further eventuated from the meeting. A few…