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HARKNESS v. UNITED STATES

No. 316-65.

469 F.2d 310 (1972)

Rebekah HARKNESS v. The UNITED STATES.

United States Court of Claims.

As Amended December 1, 1972.

As Amended February 2, 1973.

Attorney(s) appearing for the Case

James A. Glascock, Jr., New York City, for plaintiff. Weston Vernon, Jr., New York City, attorney of record. Clarence E. Dawson, Washington, D. C., of counsel.

Milan D. Karlan, with whom was Asst. Atty. Gen. Scott P. Crampton, for defendant. Philip R. Miller and Joseph Kovner, Washington, D. C., of counsel.

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

OPINION

PER CURIAM:*

In her 1955 federal income tax return, plaintiff included in her gross income $413,379.04 as income received during that year from her husband's estate. In 1961, the District Director of Internal Revenue for the Manhattan District, New York, took the position that, instead of such sum, plaintiff should have included the amount of $630,740.04, i. e., an additional...

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