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IRS Is Debtor

An account stated arises when the IRS (the debtor) submits to the taxpayer (the creditor) a statement of the final balance due, and the taxpayer agrees to accept the proposed balance to close the account. This creates an implied contract based on common law concepts. Suits can be brought on accounts stated between the IRS and taxpayers regarding balances due.

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1K views1 page

IRS Is Debtor

An account stated arises when the IRS (the debtor) submits to the taxpayer (the creditor) a statement of the final balance due, and the taxpayer agrees to accept the proposed balance to close the account. This creates an implied contract based on common law concepts. Suits can be brought on accounts stated between the IRS and taxpayers regarding balances due.

Uploaded by

api-3744408
Copyright
© Attribution Non-Commercial (BY-NC)
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOC, PDF, TXT or read online on Scribd
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35.18.8.

2 (10-18-1994)
Suits on Account Stated
“…Generally speaking, an account stated is based on the common law
concept that an implied contract arises when the debtor (the Service)
submits to the creditor (the taxpayer) a statement of the final balance due
on an account and the credit agrees to accept the proposed balance to
close the account. See Bonwit Teller & Co. v. United States, 283 U.S. 258
(1931. …”

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