ESTATE of W. R. LOVETT, William D. Lovett, Laurence D. Lovett, and Radford D. Lovett, Personal Representatives
v.
The UNITED STATES.
United States Court of Claims.https://leagle.com/images/logo.png
May 14, 1980.
May 14, 1980.
Attorney(s) appearing for the Case
Sheldon S. Cohen, Washington, D. C., attorney of record, for plaintiff. Lester G. Fant, III, Roger A. Pies and Cohen & Uretz, Washington, D. C., of counsel.
Kevin B. Shea, Washington, D. C., with whom was Asst. Atty. Gen. M. Carr Ferguson, for defendant. Theodore D. Peyser and Robert S. Watkins, Washington, D. C., of counsel.
Before COWEN, Senior Judge, and NICHOLS and KUNZIG, Judges.
United States Court of Claims.
OPINION
COWEN, Senior Judge.
William R. Lovett1 (taxpayer) brought suit here in June 1974 seeking a refund of an alleged overpayment of $803,440.25 in federal income taxes and assessed interest for his taxable year 1963. The petition sets forth two different claims involving a variety of issues, but only one question is presented by the taxpayer's motion for summary judgment and the defendant's cross-motion for partial summary...
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