Fromson v. United States

OPINION

YOCK, Judge.

This tax case is before the Court on cross-motions for summary judgment pursuant to RCFC 56. In this action, the plaintiffs seek to recover an alleged overpayment of taxes for the tax year ending December 31, 1986, in the amount of $2,406,916.1 As the basis of their claim, the plaintiffs allege that their 1986 income should not include a cashier’s check in the amount of $4,813,833 that the plaintiffs received on December 30, 1986, in partial payment of a judgment in the plaintiffs’ favor.2 The Government argues that the plaintiffs’ 1986 income should include the cashier’s…