Hope v. United States

OPINION

HORN, Judge.

On August 10, 1989, the plaintiffs, Grover H. Hope and Mary L. Hope, filed their original complaint under section 7422 of the Internal Revenue Code (26 U.S.C. § 7422 (1988)), claiming entitlement to the refund of income taxes, interest and penalties, they assert were “erroneously” and “illegally” assessed and collected with respect to the calendar years 1984, 1985 and 1986. The plaintiffs claim a charitable contribution deduction, pursuant to 26 U.S.C. § 170(a), (c) (1982 & Supp. II 1984), resulting from what plaintiffs allege was a “bargain sale” of Grover Hope’s property…