Naporano Iron & Metal Co. v. United States

OPINION

TIDWELL, Judge:

This is a tax refund case wherein plaintiffs seek a refund of $459,623.65 plus statutory interest for taxes and assessed interest paid in the tax years 1974-1975. The dispute arises from defendant’s actions in disallowing a $196,500 deduction by plaintiff corporation under section 162 of the Internal Revenue (IRC) for expenses allegedly paid as compensation for injuries and in settlement of a law suit and in charging the remaining plaintiffs with constructive dividends. Plaintiffs paid the additional taxes assessed by defendant for tax years 1974-75 and requested a…