MOLONEY v. UNITED STATES

Nos. 74-1621, 74-1763.

521 F.2d 491 (1975)

Paul S. MOLONEY and Roman Gruber, Executor of the Estate of Dora M. Moloney, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee (two cases).

United States Court of Appeals, Sixth Circuit.

Certiorari Denied December 8, 1975.


Attorney(s) appearing for the Case

John Kennedy Lynch, Cleveland, Ohio, for Moloney and Gruber.

Frederick M. Coleman, U. S. Atty., Cleveland, Ohio, Scott P. Crampton, Asst. Atty. Gen., Ernest J. Brown, Richard M. Roberts, Gilbert E. Andrews, Elmer Kelsey, Ann Belanger Durney, Tax Div., Dept. of Justice, Washington, D. C., for U. S.

Before PECK and ENGEL, Circuit Judges, and O'SULLIVAN, Senior Circuit Judge.


Certiorari Denied December 8, 1975. See 96 S.Ct. 452.

ENGEL, Circuit Judge.

This tax refund suit in the district court arises from a deficiency assessed by the government against Paul S. Moloney and Dora M. Moloney1 in the amount of $50,771.75 in unpaid income taxes for the year 1952. Taxpayers appeal from a partial summary judgment entered in favor of the government in the amount of $35,000.00, and the government appeals from...

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