Gerald Johnson v. United States of America, United States of America v. Gerald Johnson

Plaintiff, taxpayer, brought this suit to recover sums overpaid as taxes and fraud penalties for the years 1941, 1942, and 1943, aggregating $98,970.33.

The United States, in addition to opposing defenses to the suit, filed a counterclaim for deficiencies in income taxes for the years 1944, 1945, and 1946, assessed against the plaintiff on March 21, 1952, aggregating $55,155.90, and plaintiff replied thereto.

Thereafter the issues thus joined were tried to the court without a jury, and, the evidence concluded, the district judge, stating:

“I find there is no merit whatever in the plaintiff’s…