Corbett

Frank, Director of Internal Revenue for the District of Washington, claims Donald Corbett owes him federal income taxes for the year 1845 on his separate return in the amount of $12,000 plus interest, and that his wife, Georgia Corbett, for the same year on her separate return, owes the same amount. After sixteen years the interest about equals the principal.

Then the director on the joint return of the Corbetts for 1953 asserts $14,000 is due. Here the interest has not caught up with the principal yet.

Also, for the years 1945 and 1953, the director asserts penalties for false claim of credits on the three returns.

As to each return, the director during 1956 gave the usual 30-day letter setting forth his intention to assess. 1 However, he split the amounts he claimed to be due on each return, and he gave 90-day letters (statutory notices of deficiency) to the taxpayers on the penalties. 2 3 (These 90-day letters are popularly called “tickets to the tax court.”) 3 But the director *503 claims that he can proceed to assessment of all principal and interest, 4 which he says are unpaid, just as if the taxpayers had made on their returns mathematical errors in their favor, and that…