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COLEBANK v. COMMISSIONER

Docket No. 3024-75.

36 T.C.M. 200 (1977)

T.C. Memo. 1977-46

John W. and Mary C. Colebank v. Commissioner.

United States Tax Court.

Filed February 23, 1977.

Attorney(s) appearing for the Case

John W. Colbank, pro se, 5865 Pebble Beach Ave., Memphis, Tenn. Robert W. West, for the respondent.

Memorandum Findings of Fact and Opinion

QUEALY, Judge:

Respondent determined a deficiency in petitioners' Federal income tax in the amount of $2,896.83 for the taxable year 1972.

The only issue for decision is whether the Internal Revenue Service's negotiation of petitioners' check for $500.00 marked as being in full payment of petitioners' 1972 taxes constituted a compromise settlement of petitioners' 1972 income tax liability.

Findings...

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