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JONES v. U.S.

No. 5:93 CV 0680.

857 F.Supp. 587 (1994)

Sam B. JONES, et al., Plaintiffs, v. The UNITED STATES of America, Defendant.

United States District Court, N.D. Ohio, Eastern Division.

April 22, 1994.

Attorney(s) appearing for the Case

Bernard D. DelGuzzi, DelGuzzi & Scavdis, Ravenna, OH, for Sam B. Jones and Louanna Jones.

Alan M. Shapiro, Dept. of Justice — Tax Div., Washington, DC, for U.S.

MEMORANDUM OPINION

DOWD, District Judge.

I. BACKGROUND

Plaintiffs, Sam B. Jones and Louann B. Jones, contend that the United States improperly assessed $100,000 of taxable income against them for the 1981 tax year. Plaintiffs seek a refund of federal income taxes, penalties, and interest claiming that they never received any portion of the $100,000 paid in consideration of a covenant not to compete. 28 U.S.C. § 1346(a). The United States...

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