Geiger v. Commissioner

refusing to impute Florida prosecutor’s knowledge of the indictment of an important government witness that was unsealed a week before trial in New York | refusing to impute knowledge of Florida prosecutor to Assistant United States Attorney in New York, and rejecting as “completely untenable [the] position that knowledge of any part of the government is equivalent to knowledge on the part of this prosecutor” | settlement contracts “will be upheld whenever possible because they are a means of amicably resolving doubts and uncertainties and preventing lawsuits.” | U.S. Attorney in Southern District of New York not charged with knowledge of sealed indictment in Southern District of Florida against principal government witness | uncontradicted evidence from taxpayer does not necessarily operate to overcome the presumption of correctness | uncontradicted evidence from taxpayer does not necessarily operate to overcome the presumption of correctness