Owen L. Lamb and Nancy G. Lamb v. Commissioner of Internal Revenue

Petitioners seek to set aside a decision of the Tax Court of the United States upholding a determination which had been made by respondent that petitioners were liable for an income tax deficiency of $194.99 for the taxable year 1962.

The underlying issues presented to us by petitioners are set forth in the reported opinion of the Tax Court of August 2, 1966, 46 T.C. 539. And see our opinion of March 9,1967 denying a motion to dismiss the petition, 374 F.2d 256 (2 Cir. 1967).

On December 5, 1966, pursuant to the Tax Court decision, petitioners paid the $194.99 and accrued interest of $42.28 to…