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GOODWIN v. UNITED STATES

No. 309-70.

458 F.2d 108 (1972)

Robert F. GOODWIN et al. v. The UNITED STATES.

United States Court of Claims.

April 14, 1972.

Attorney(s) appearing for the Case

James A Lorentzen, Des Moines, Iowa, atty. of record, for plaintiffs. Roy M. Irish, Patterson, Lorentzen, Duffield, Timmons & Irish, Des Moines, Iowa, of counsel.

Ira Mark Bloom, Washington, D. C., with whom was Asst. Atty. Gen. Scott P. Crampton, for defendant. Philip R. Miller, Washington, D. C., of counsel.

Before COWEN, Chief Judge, and DAVIS, COLLINS, SKELTON, NICHOLS, KASHIWA and KUNZIG, Judges.

OPINION

COWEN, Chief Judge.*

Plaintiffs seek to recover federal income taxes collected for the calendar years 1964, 1965, and 1966, plus statutory interest. The suit arises as a result of defendant's determination that the deduction provided by section 691(c) of the Internal Revenue Code of 19541 is not allowable as a deduction from ordinary income, but may only be taken to reduce the amount included...

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