Marshall M. Chernin Ida Raye Chernin, Cross-Appellants/appellees v. United States of America, Appellant/cross-Appellee

GOLDBERG, District Judge.

This is a tax refund dispute. Marshall M. Chernin (“taxpayer”) and Ida Raye Chernin, his wife, filed this action, seeking a refund for taxes levied and collected by the Internal Revenue Service (“IRS”) during the years 1979 to 1983. 2 Taxpayer asserts that refunds are due for taxes paid on income reported in 1982 on two alternative grounds: either because (1) in 1982, he lost the unrestricted right to funds that he had previously claimed as income; or (2) in 1982 he transferred funds to contest an “asserted liability.” The United States counters that taxpayer does not…