Plitt v. Hofferbert

THOMSEN, Chief Judge.

This action was brought by plaintiff taxpayer to recover income taxes for the years 1925 to 1936, inclusive, with interest and penalties, alleged to have been erroneously and illegally collected by defendant collector. The government filed a motion for leave to intervene in this action in order to assert a claim against taxpayer which is not open to defendant collector. The government’s counterclaim is for additional income taxes, penalties and interest for the years 1925 through 1930 and 1932 through 1934. A deficiency notice for these additional taxes was sent to the…