George A. Angle v. United States

LOGAN, Circuit Judge.-

George A. Angle (taxpayer) appeals from the decision of the district court dismissing his federal income tax refund suit for lack of subject matter jurisdiction.

Taxpayer filed a timely income tax return for 1982. That year plaintiff was subject to the “add-on” minimum tax under then I.R.C. § 56(a) 1 and filed with his return a Form 4625 for the purpose of computing his minimum tax liability. On this form, he reported' a $453,638 tax preference for intangible drilling costs. In 1984, plaintiff filed a timely refund claim seeking to reduce the amount of intangible drilling…