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CLEVELAND CHAIR CO. v. UNITED STATES

No. 75-1451.

526 F.2d 497 (1975)

CLEVELAND CHAIR COMPANY and William R. Jackson, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided December 8, 1975.

Attorney(s) appearing for the Case

Richard Jahn, Tanner & Jahn, Chattanooga, Tenn., for plaintiffs-appellants.

John L. Bowers, U.S. Atty., Chattanooga, Tenn., Scott P. Crampton, Gilbert E. Andrew, Richard A. Scully, David English Carmack, Alfred S. Lombardi, Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellee.

Before PHILLIPS, Chief Judge, and CELEBREZZE and McCREE, Circuit Judges.

PHILLIPS, Chief Judge.

This litigation is a sequel to Jackson v. Commissioner, 380 F.2d 661 (6th Cir. 1967), cert. denied, 389 U.S. 1015, 88 S.Ct. 591, 19 L.Ed.2d 661 (1967). In the earlier case this court affirmed a United States Tax Court decision upholding an income tax assessment of approximately $1,400,000.

As a condition of stay of assessment and collection of...

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