Donald G. Ford, Transferee v. United States

In the taxpayer’s suit for recovery of income taxes alleged to have been illegally assessed and collected, the Government did not rebut the evidence that bad debt recoveries were improperly retained in the company’s income, but defended on the technical ground that there was a variance between the refund claim and the evidence and that the claim was not sufficiently specific to comply with the statute and the regulation. 26 U.S.C. 1964 ed., § 7422; 26 C.F.R., Sec. 1.11-1.

We agree with District Judge Gordon that there was no variance and that the refund claim was sufficiently specific to…