Rice v. United States

OPINION

LYDON, Judge:

This tax case involves a suit for refund of certain income taxes, plus interest. The sole issue before the court concerns the propriety of the assessment and collection by the Internal Revenue Service of a deficiency in income tax, plus interest, based on an increase in plaintiff’s long-term capital gains for 1977 of some $149,966.00 relative to the transfer of certain securities. The actual amount of tax in controversy, according to plaintiff, “has not been precisely calculated” as to this specific matter, but is estimated by plaintiff to be in excess of $50,000.

I

Plaintiff…