United States Court of Claims January 21, 1983, Nos. 389-79T to 393-79T, 395-79T and 396-79T (Garvey, Inc. v. United States)

OPINION

PHILIP R. MILLER, Judge:

The corporate and individual plaintiffs in these consolidated cases filed suit to recover an aggregate of $3,447,102 in federal income taxes paid for 1969 through 1977. The cases present issues relating to consolidated return regulations and private annuities. The facts on all issues have been stipulated and insofar as pertinent are stated in the opinion.