Brigham v. United States

The four suits listed above were consolidated by an order of this court. The suits were brought to recover income taxes and assessed interest for the years and amounts indicated,1 plus interest as provided by law. The defendant has moved for judgment on the pleadings. The plaintiffs oppose the motion, raising three separate and distinct issues for our resolution:(1) Whether the provisions of sections 1311 to 1315 of the Internal Bevenue Code of 1954 apply in mitigation of the otherwise applicable statute of limitations on refunds with respect to the taxable years in issue.(2) Whether,…