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SOTIR v. U.S.

No. 92-1061.

978 F.2d 29 (1992)

Samuel V. SOTIR and Norman P. Johnson, Plaintiffs, Appellants, v. UNITED STATES of America, Defendant, Appellee.

United States Court of Appeals, First Circuit.

Decided October 30, 1992.

Attorney(s) appearing for the Case

Carl Emmett Baylis, Worcester, Mass., was on brief, for plaintiffs, appellants.

Christine A. Grant, Atty., Dept. of Justice, Washington, D.C., with whom A. John Pappalardo, U.S. Atty., Boston, Mass., James A. Bruton, Acting Asst. Atty. Gen., Gary R. Allen, Atty., Dept. of Justice, and Richard Farber, Atty., Dept. of Justice, Washington, D.C., were on brief, for defendant, appellee.

Before TORRUELLA, CYR, and BOUDIN, Circuit Judges.

BOUDIN, Circuit Judge.

The sole question presented on this appeal is whether, when a taxpayer with several tax liabilities sends a payment to the Internal Revenue Service but fails to specify the liability to which the payment applies, the IRS may apply the payment to the liability it chooses. In agreement with the district court in this case and in accord with other circuits, we hold that the IRS may make this choice.

Samuel V. Sotir and Norman P. Johnson...

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