Brown v. United States

FINDINGS OF FACT, OPINION AND CONCLUSIONS OF LAW

CARL B. RUBIN, District Judge.

I

FINDINGS OF FACT(1) Plaintiffs Wayne E. Brown and Mary Ruth Brown, husband and wife, filed a joint tax return for the year 1964. A deficiency in the sum of $10,216.43 was assessed against them for the year 1964 by the Internal Revenue Service and the deficiency was subsequently paid. A timely claim for refund of the deficiency assessed and paid was filed by the plaintiffs and subsequently disallowed by the Internal Revenue Service. On July 12, 1968, the complaint in the above entitled matter was filed in the United…