JACOBS v. UNITED STATES

No. 483-52.

126 F.Supp. 154 (1954)

Saul B. JACOBS v. The UNITED STATES.

United States Court of Claims.

November 30, 1954.


Attorney(s) appearing for the Case

John R. Stivers, Memphis, Tenn., for plaintiff. Lowrance & Stivers, Memphis, Tenn., were on the briefs.

J. W. Hussey, Washington, D. C., with whom was Asst. Atty. Gen. H. Brian Holland, for defendant. Andrew D. Sharpe and Robert N. Anderson, Washington, D. C., were on the brief.

Before JONES, Chief Judge, and LITTLETON, WHITAKER, MADDEN and LARAMORE, Judges.


JONES, Chief Judge.

Plaintiff brought this action to recover $293,759.50 taxes, penalties, and interest which he alleges the defendant has collected illegally.

Plaintiff filed returns, on a fiscal year basis (ending October 31), for each of the years 1944, 1945, 1946 and 1947. The Commissioner of Internal Revenue made deficiency assessments using an increase in net worth computation for these same years. He subsequently collected the deficiency together with...

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