Jeanese, Inc. v. United States

JERTBERG, Circuit Judge.

Appellants appeal from a judgment of the District Court denying appellants’ claim against the United States for a refund of alleged overpayment of Federal Income Taxes paid by them for the fiscal period commencing February 1, 1957 and ending January 16, 1958. The decision of the District Court is reported at 227 F.Supp. 304 (1964). The facts were in large measure stipulated by the parties.

The record may be summarized as follows : In 1953, four individuals formed a partnership and acquired King Ranch, a parcel of land of approximately 90 acres near Los Altos,…