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BOWLES v. U.S.

No. 86-2583.

820 F.2d 647 (1987)

Michael E. BOWLES; Lynn G. Bowles, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided June 3, 1987.

Attorney(s) appearing for the Case

Douglas E. Little, Charlottesville, Va. (Robert M. Musselman, on brief), for plaintiffs-appellants.

Michael B. Rappaport, Tax Div., Dept. of Justice, Washington, D.C. (Roger M. Olsen, Asst. Atty. Gen., Michael L. Paup and Richard Farber, on brief), for defendant-appellee.

Before SPROUSE and ERVIN, Circuit Judges, and HAYNSWORTH, Senior Circuit Judge.

SPROUSE, Circuit Judge:

Michael E. Bowles and Lynn G. Bowles, his wife, appeal from the district court's dismissal of their tax refund suit. The Bowles had attempted to assert claims for business-expense deductions incurred while away from their tax home claimed to be in Charlottesville, Virginia. The district court ruled that it lacked jurisdiction to hear these claims because the Bowles failed to assert in their administrative refund claim that Charlottesville was...

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