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BROWN v. UNITED STATES

Civ. A. No. C82-0075-O(J).

600 F.Supp. 47 (1984)

Clyde BROWN, Jr., Plaintiff, v. UNITED STATES, Defendant.

United States District Court, W.D. Kentucky, Owensboro Division.

October 18, 1984.

Attorney(s) appearing for the Case

Jesse T. Mountjoy of Holbrook, Gary, Wible & Sullivan, Owensboro, Ky., for plaintiff.

David T. Gray, Asst. U.S. Atty. for the Western District of Ky., Louisville, Ky., and Michael J. Salem of the U.S. Dept. of Justice, Tax Division, Washington, D.C., for defendant.

MEMORANDUM OPINION

JOHNSTONE, District Judge.

The Internal Revenue Service audited Plaintiff Clyde Brown and assessed an income tax deficiency of $57,397.86 on his 1976 tax return. Brown paid the deficiency and filed for a refund of $26,624.31 which was disallowed by the Commissioner of Internal Revenue (Commissioner). He then filed this suit against the United States under 28 U.S.C. § 1346(a)(1) for recovery...

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