Jamy Corporation, a California Corporation v. Robert A. Riddell, Individually and as District Director of Internal Revenue, Los Angeles, California

CHAMBERS, Circuit Judge.

The district court has denied appellant a decree enjoining collection of income taxes claimed by the appellee-defendant for two fiscal years ending in 1956 and 1957. We affirm.

The judgment below resulted from an attack on plaintiff’s complaint. Again, we are confronted with the paradoxical situation that the rules for the Southern District of California provide for findings of fact and conclusions of law on summary judgments when the very essence of a summary judgment is that there are no facts in dispute. Such an adherence to form perhaps does no harm when it is used…