R. C. Hoskins v. United States of America, R. C. Hoskins, Plaintiff-Cross-Appellant v. United States of America, Defendant-Cross-Appellee

This action was commenced by the taxpayer in the United States District Court for the Eastern District of Tennessee to recover amounts he paid the Government under a compromise tax agreement entered into pursuant to Section 7122 of the Internal Revenue Code of 1954, 26 U.S.C. § 7122 (1964). Federal jurisdiction was invoked pursuant to 28 U.S.C. § 1346(a) (1) (1964).

The District Court found that the taxpayer was entitled to a refund with regard to certain property acquired by the Appellant with his own funds after and apart from the obligations arising under the compromise agreement entered…