Skinner v. United States

FINDINGS OF FACT AND CONCLUSIONS OF LAW

GUIN, District Judge.

INTRODUCTION

This is an action by Thomas E. and Margaret S. Skinner (“the Skinners”) 1 to recover an aggregate sum of $18,614.-90, together with interest as allowed by law, as a refund of federal income taxes which they contend were wrongfully assessed for the years 1970 and 1971. Deficiency assessments for the years in question were based upon a determination by the Internal Revenue Service that certain income reported by the Skinners as long-term capital gain from a sale of stock in Fidelity Service Insurance Company (“Fidelity”)…