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PARAMOUNT FINANCE COMPANY v. UNITED STATES

Nos. 2-59, 3-59.

304 F.2d 460 (1962)

The PARAMOUNT FINANCE COMPANY v. The UNITED STATES. Edward T. KIRTZ and Rosalyn S. Kirtz v. The UNITED STATES.

United States Court of Claims.

June 6, 1962.

Attorney(s) appearing for the Case

Harlan Pomeroy, Washington, D. C., for plaintiffs. Norman A. Sugarman, Cleveland, Ohio, on the briefs.

S. Laurence Shaiman, Washington, D. C., with whom was Acting Asst. Atty. Gen., John B. Jones, Jr., for defendant. Lyle M. Turner, Philip R. Miller, and Eugene Emerson, Washington, D. C., on the brief.

LARAMORE, Judge.

This suit arises from the determination of a deficiency in plaintiffs' income taxes assessed and collected by the Internal Revenue Service. The plaintiffs in this action are Edward T. Kirtz and Rosalyn S. Kirtz (hereinafter referred to as Kirtz), and the Paramount Finance Company (hereinafter referred to as Paramount).

At all times material Kirtz was an insurance agent duly licensed by the Ohio Superintendent...

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