Grob, Inc. v. United States

DECISION AND ORDER

WARREN, District Judge.

I. BACKGROUND

These proceedings began with a letter of April 18, 1979, from the Internal Revenue Service (IRS) to the plaintiff, indicating a needed adjustment to the tax liability of' Grob, Inc. for fiscal year 1976, ending September 30, 1976, and fiscal year 1977, ending September 30, 1977. The taxpayer opposed the assessment, paid the same on April 28, 1980, and filed a claim for refund on May 22, 1980. Following denial of the claim by the Government, this action was commenced on December 10, 1980. Trial was held, and the taxpayer was awarded…