Holdeen v. Ratterree

LEONARD P. MOORE, Circuit Judge.

Plaintiff-appellant, Jonathan Holdeen, brought suit against Riley J. Ratterree, as Late District Director and Fulton D. Fields, as Late Acting Director of Internal Revenue (usually referred to as the “government”), to recover amounts which he claimed had been wrongfully and illegally collected as taxes on his income for the calendar year 1945. In the ninety-day letter containing a statement of determination of deficiency, the Commissioner gave as one reason for the *702additional tax that, with respect to “ordinary income and net capital gains alleged to have been…