United States Court of Claims January 30, 1989, No. 645-85T (Mulholland v. United States)

OPINION

REGINALD W. GIBSON, Judge:

INTRODUCTION

Kenneth and Catherine Mulholland, husband and wife (taxpayers/plaintiffs herein), filed the instant tax refund suit on October *25330, 1985, seeking a refund of federal income taxes assessed by the Commissioner of Internal Revenue (Commissioner) against their joint individual income tax returns for taxable years 1981 and 1982.