Woodward v. United States

SANBORN, Circuit Judge.

The Commissioner of Internal Revenue assessed deficiencies in the federal income taxes of F. W. Woodward, of Du-buque, Iowa, for the years 1944, 1945, and 1946, based upon the disallowance of certain claimed deductions. The taxpayer paid the additional taxes assessed, made timely claims for refund, and, upon their denial, brought this action under § 1346(a) (1), Title 28 U.S.C.A., asserting that the deficiencies had been illegally assessed.

The deductions disallowed by the Commissioner, with which this Court is concerned, involved amounts paid by the taxpayer to his wife…