MARTIN v. MACHIZ

Civ. No. 15740.

251 F.Supp. 381 (1966)

Pannill MARTIN and Mary Martin, Plaintiffs, v. Irving MACHIZ, District Director of Internal Revenue for the District of Maryland, Defendant.

United States District Court D. Maryland.

March 9, 1966.


Attorney(s) appearing for the Case

William A. Grimes, Frank B. Ober, Ober, Williams & Grimes, Baltimore, Md., for plaintiffs.

Moshe Schuldinger, Atty., Dept. of Justice, Richard M. Roberts, Acting Asst. Atty. Gen., David A. Wilson, Jr., Atty., Dept. of Justice, Washington, D. C., Thomas J. Kenney, U. S. Atty., and Robert W. Kernan, First Asst. U. S. Atty., Baltimore, Md., for defendant.


WINTER, District Judge:

Mr. and Mrs. Pannill Martin (taxpayers) sue to recover income taxes and interest assessed, in the total amount of $298,959.68, for the calendar years 1959 and 1960. During those years taxpayers, individually and not jointly, were the majority stockholders of The Cloverdale Spring Company (Cloverdale), a soft drink bottling company. The assessments were made by charging to taxpayers' income a proportionate share of the payment of $3,000.00 by...

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