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GIRARD v. GILL

No. 7329.

243 F.2d 166 (1957)

Cy GIRARD, Sam R. Girard, Herbert A. Girard, as Executors of the Estate of Frank Goldberg, Deceased, and Sadie P. Goldberg, Appellants, v. Edwin GILL, Formerly Collector of Internal Revenue, Appellee.

United States Court of Appeals Fourth Circuit.

Decided April 4, 1957.

Attorney(s) appearing for the Case

Morris B. Abram, Atlanta, Ga. (Charles F. Wittenstein, Atlanta, Ga., on the brief), for appellants.

Carolyn R. Just, Atty., Dept. of Justice, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson and Hilbert P. Zarky, Attys., Dept. of Justice, Washington, D. C., and Edwin M. Stanley, U. S. Atty., Greensboro, N. C., on the brief), for appellee.

Before PARKER, Chief Judge, SOBELOFF, Circuit Judge, and WILLIAMS, District Judge.

PER CURIAM.

This case is one of a group of six in which joint counsel for the taxpayers negotiated with the Commissioner of Internal Revenue for settlement of proposed deficiencies or overpayments. This particular case involved a deficiency. A single proposal was orally submitted by the taxpayers' counsel to cover the entire group of cases. The agreement, informally reached, was reduced to formal offers on Treasury Form 870-TS, and on the back of each form it was...

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