Johnson v. United States

URBOM, Chief Judge.

Glenn E. Johnson and Barbara Johnson have brought this action to recover taxes and interest which they contend the Internal Revenue Service erroneously or illegally assessed. Count I concerns the plaintiffs’ 1977 tax return, Count II the 1978 return. In both years the plaintiffs claimed certain business deductions which the IRS disallowed. The plaintiffs paid the deficiencies which the IRS assessed, filed timely claims for refunds, and brought this lawsuit under 26 U.S.C. § 7422 after their claims were rejected. This court has jurisdiction under 28 U.S.C. § 1346(a)(1). The…