Cleveland Chair Co. v. United States

PHILLIPS, Chief Judge.

This litigation is a sequel to Jackson v. Commissioner, 380 F.2d 661 (6th Cir. 1967), cert. denied, 389 U.S. 1015, 88 S.Ct. 591, 19 L.Ed.2d 661 (1967). In the earlier ease this court affirmed a United States Tax Court decision upholding an income tax assessment of approximately $1,400,000.

As a condition of stay of assessment and collection of taxes pending appeal in the former case, the taxpayers were required by the Tax Court to post security pursuant to 26 U.S.C. § 7485. United States Treasury notes in the amount of $995,000 were deposited with the Clerk of the United…