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CLARK v. KAVANAGH

No. 3856.

59 F.Supp. 806 (1944)

CLARK et al. v. KAVANAGH, Collector of Internal Revenue.

District Court, E. D. Michigan, S. D.

November 30, 1944.

Attorney(s) appearing for the Case

Butzel, Eaman, Long, Gust & Bills, of Detroit, Mich., for plaintiff.

John C. Lehr and Arnold W. Lungerhausen, both of Detroit, Mich. (Samuel O. Clark, Jr., Andrew D. Sharpe, and Leland T. Atherton, all of Washington, D. C., on the brief), for the Government.

Findings of Fact

LEDERLE, District Judge.

1. This is an action seeking refund of a 1939 income tax deficiency of $20,562.81 levied by the Commissioner of Internal Revenue and paid by the taxpayers, Emory W. Clark and wife, plaintiffs herein, to the defendant, Giles Kavanagh, Collector of Internal Revenue for this District. As the transactions involved relate solely to plaintiff Emory W. Clark, for brevity he will

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