Frank Erickson and Amelia Erickson v. The United States

DAVIS, Judge.

This is primarily a suit for refund of interest, collected on delayed tax payments, which* the plaintiffs would deny to the Government because of the special history of their prior tax litigation. The case has its origin in the income tax returns filed by Frank Erickson, the taxpayer, 1 for the years 1937-1950 (exclusive of 1941). In January 1951, on the ground that the returns were fraudulent, the Commissioner of Internal Revenue made jeopardy assessments of tax, fraud penalty, and deficiency interest for each of the years 1937-1946 (except 1941) in large sums varying in amount…