GENERAL SPLIT CORPORATION v. UNITED STATES

No. 73-2002.

500 F.2d 998 (1974)

GENERAL SPLIT CORPORATION, a Wisconsin corporation, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided July 17, 1974.


Attorney(s) appearing for the Case

George J. Laikin and Joseph I. Swietlik, Milwaukee, Wis., for plaintiff-appellant.

Scott P. Crampton, Asst. Atty. Gen., Libero Martinelli, Jr., Atty., Tax Div., U. S. Department of Justice, Washington, D. C., David J. Cannon, U. S. Atty., Milwaukee, Wis., for defendant-appellee.

Before PELL, STEVENS and SPRECHER, Circuit Judges.


SPRECHER, Circuit Judge.

This case presents the question of whether a settlement agreement, effected by, inter alia, the execution of a Form 870-AD equitably estopped the taxpayer from later seeking a refund of deficiencies paid as part of the settlement.

I

Commencing with its organization in 1955, the taxpayer entered into a loan agreement with Kivie Kaplan (Kaplan Loan) providing for a loan of ...

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