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UNITED STATES v. SALADOFF

June 26, 1964

UNITED STATES of America
v.
Sara SALADOFF, Administratrix of Estate of Joseph Saladoff, Dec'd



The opinion of the court was delivered by: HIGGINBOTHAM

.on March 12, 1954, plaintiff-United States (government) made assessments against defendant's testator, Joseph Saladoff, (taxpayer) *fn1" for the tax years 1948, 1949 and 1950 in the amounts of $ 11,108.06, $ 8,078.70 and $ 3,120.10, respectively.

On April 18, 1956, the government accepted taxpayer's offer to compromise these assessments for the sum of $ 15,000.00, with $ 7500.00 to be paid within one year and the balance ($ 7500.00) payable in monthly installments of $ 300.00 beginning on the thirteenth month after the acceptance of the agreement. Also incorporated in the agreement -- which was on Standard Form 656C, as required by law *fn2" -- was the following default provision:

 'As a part of this offer, it is agreed that upon notice to the proponent of the acceptance of this offer in compromise of the liability aforesaid, the proponent shall have no right, in the event of default in payment of any installment of principal or interest due under the terms of the offer, to contest in court or otherwise the amount of the liability sought to be compromised, and that in the event of such default the Commissioner of Internal Revenue, at his option, (1) may proceed immediately by suit to collect the entire unpaid balance of the offer, or (2) may disregard the amount of such offer and apply all amounts previously paid thereunder against the amount of the liability sought to be compromised and may, without further notice of any kind, assess and/or collect by distraint or suit (the restrictions against assessment and/or collection being hereby specifically waived) the balance of such liability.'

19640626

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