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PHILLIPS v. COMMISSIONER OF INTERNAL REVENUE

Nos. 9969 to 9977.

178 F.2d 270 (1949)

PHILLIPS et al. v. COMMISSIONER OF INTERNAL REVENUE and eight other cases.

United States Court of Appeals, Third Circuit.

Decided December 2, 1949.

Attorney(s) appearing for the Case

Sidney B. Gambill, Pittsburgh, Pa. (Rolland L. Ehrman, Butler, Pa., W. A. Seifert, William Wallace Booth, and Reed, Smith, Shaw & McClay, Pittsburgh, Pa., on the brief), for petitioners.

Hilbert P. Zarky, Sp. Asst. Atty. Gen., Washington, D. C. (Theron Lamar Caudle, Asst. Atty. Gen. and Ellis N. Slack, Sp. Asst. Atty. Gen. on the brief), for respondent.

Before GOODRICH, McLAUGHLIN and KALODNER, Circuit Judges.

PER CURIAM.

In these cases the petitioners seek to bring before us the effect of a closing agreement made between a taxpayer and the Commissioner. 26 U.S.C.A. § 3760. The agreement in these cases, however, was entered into between a corporate taxpayer and the Commissioner upon Form 866, which does not purport by its terms to settle anything more than the amount of taxpayer's liability for a particular year or years. We see nothing to indicate that the use of...

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