MALONEY v. COLLISON

Civ. A. No. 1451.

119 F.Supp. 12 (1954)

MALONEY v. COLLISON et al.

United States District Court, D. Delaware.

February 24, 1954.


Attorney(s) appearing for the Case

Edward W. Cooch, Jr., and Edwin D. Steel, Jr., of Morris, Steel, Nichols & Arsht, Wilmington, Del., for plaintiff.

Leonard G. Hagner, U. S. Atty., Wilmington, Del., H. Brian Holland, Asst. Atty. Gen., Andrew D. Sharpe and Robert Margolis, Sp. Assts. to the Atty. Gen., for defendants.


LEAHY, Chief Judge.

Suit was brought against former Collectors and present Director of Internal Revenue to recover income taxes and interest plaintiff paid under deficiency assessments. For 1946, $27,296.23 was in issue, and for 1947, $16,596.89, both plus interest. Validity of the assessments hinges on the bona fides of a partnership formed October 15, 1945, by plaintiff, his wife and son.

The case was tried by jury. Plaintiff's motion for a directed verdict...

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