August E. Sorrentino v. A. C. Ross, United States District Director of Internal Revenue for the District of Georgia

AINSWORTH, Circuit Judge:

Taxpayers appeal from a judgment of the District Court granting the Government’s motion for summary judgment and dissolving a temporary injunction restraining the collection of unpaid tax assessments for the taxable years 1957 and 1958. Appellants contend that the tax deficiency notice addressed to them was legally insufficient and that a stipulation and subsequent Tax Court consent decision based thereon were invalid for the reason that their counsel who signed the stipulation in their behalf lacked the requisite authority by reason of not having filed with the Tax…