Robert G. Dudley v. United States

TRASK, Circuit Judge:

This is an appeal from a judgment of the District Court denying appellant’s claim for refund of tax in the amount of $3734.24 collected from him by the Internal Revenue Service pursuant to 26 *1198U.S.C. § 66721 and granting the United States’ counterclaim in the amount of $9258.37 representing the difference between the amount of tax assessed against appellant and the amount collected. The District Court’s opinion is reported at 285 F.Supp. 979 (N.D.Cal.1967).

In 1960, appellant was president and, along with his wife, principal stockholder of the Dudley Industrial Corporation,…