Harkness v. United States

PeR Curiam:*

In her 1955 federal income tax return, plaintiff included in her gross income $413,379.04 as income received during that year from her husband’s estate. Tn 1961, the District Director of Internal Revenue for the Manhattan District, New York, took the position that, instead of such sum, plaintiff should have included the amount of $630,740.04, i.e., an additional $217,361. The inclusion of such larger amount in plaintiff’s gross income resulted (after the making of various adjustments) in plaintiff’s allegedly owing an additional $188,153.35 in income tax for such year, and the…