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GROVES v. UNITED STATES

No. 74-4219.

533 F.2d 1376 (1976)

Kenneth R. GROVES and Peggy L. Groves, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

June 25, 1976.

Attorney(s) appearing for the Case

H. Edward Moore, Jr., Larry Hill, Pensacola, Fla., for plaintiffs-appellants.

William H. Stafford, Jr., U. S. Atty., Pensacola, Fla., Scott P. Crampton, Asst. Atty. Gen., Tax Div., Dept. of Justice, Alfred S. Lombardi, Atty., Gilbert E. Andrews, Acting Chief, App. Section, Dept. of Justice, Washington, D. C., for defendant-appellee.

Before BROWN, Chief Judge, and THORNBERRY, Circuit Judge, and MILLER, Associate Judge.

MILLER, Associate Judge:

This appeal is from the judgment of the district court in favor of the United States, dismissing appellants' suit for refund of federal income taxes for the calendar years 1970 and 1971, which was based on disallowance of their claims for refund by the Internal Revenue Service. Appellants' earned income for the years involved consisted of salaries paid them by the Government of the Trust Territory of the Pacific Islands (GTTPI), and the ultimate...

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