KALIL v. ENOCHS

No. 18849.

295 F.2d 467 (1961)

Emil KALIL, Sr. et al., Appellants, v. James L. ENOCHS, Director of Internal Revenue, Appellee.

United States Court of Appeals Fifth Circuit.

October 31, 1961.


Attorney(s) appearing for the Case

deQuincy V. Sutton, Meridian, Miss., for appellants.

E. R. Holmes, Jr., Asst. U. S. Atty., Jackson, Miss., Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, Washington, D. C., Robert E. Hauberg, U. S. Atty., Jackson, Miss., John A. Bailey and Meyer Rothwacks, Attys., Dept. of Justice, Washington, D. C., for appellee.

Before RIVES, CAMERON and BROWN, Circuit Judges.


RIVES, Circuit Judge.

The complaint filed by the four appellants seeks an order directing the District Director of Internal Revenue to issue the statutory notice of deficiency,1 often referred to as the "90-day letter," for each of the taxable years 1950 through 1955, to two of the plaintiffs, Emil Kalil, Sr., and his wife, Dolly Kalil, hereinafter referred to as the "taxpayers." The other two plaintiffs are the taxpayers' son and daughter...

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