[59-2 USTC ¶9796]Eastern Tar Products Corporation by its
Directors, Grant Thorn, Genevieve U. Thorn, and
Samuel Uhlfelder, in trust for its creditors,
stcokholders and members, Appellants v. United
States of America, Appellee
(CA-4), U. S. Court of Appeals, 4th Circuit, No.
7894, 271 F2d 739, 11/23/59, affirming the
District Court, 59-1 USTC ¶9272, 170 F. Supp.
110
[1939 Code Sec. 3761(a)--same as 1954 Code Sec.
7122(a)]
Compromise: Estoppel.--A valid compromise
settlement of income, withholding and
unemployment taxes, entered into by the taxpayer
company's receiver, worked an estoppel against
the taxpayer's subsequently disputing liability.
Because the issues had been fairly and
completely presented, and the taxpayer had
personally appeared through its president, the
original compromise was res judicata of
the later proceeding.
Harry S. Shapiro, 349 N. Calvert,
Baltimore
,
Md.
, for appellants. I. Henry Kutz, Department of
Justice, Washington, D. C. (Charles K. Rice,
Assistant Attorney General, Lee A. Jackson, Fred
A. Youngman, Department of Justice, Washington,
D. C., Leon H. A. Pierson, Baltimore, Md.,
United States Attorney, on brief), for appellee.
