Michael B. Suffness, and Dorit R. Suffness v. United States

WIENER, Circuit Judge.

Plaintiffs-Appellants Michael B. and Dorit R. Suffness, husband and wife (Taxpayers) appeal the adverse judgment of the district court, rendered following the bench trial of Taxpayers’ income tax refund suit on stipulated facts. The sole issue before the court was whether Taxpayers owed interest on the amount of additional tax remitted by Taxpayers after they failed timely to reinvest, in property of like kind, the proceeds of the involuntary conversion of their corporate stock certified by the Federal Communications- Commission (FCC) to be “broadcasting property” and…