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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. …”