Jennings v. United States

STERLING HUTCHESON, District Judge.

The issues here involved may be summarized as follows:

1. Whether the plaintiffs’ operation of the restaurant trading as Starlight Grill comes within the coverage of the Federal Cabaret Tax. Section 101.14, Treasury Regulation 43.

2. If so, is the Government’s estimate of tax due arrived at by a formula devised by the Government agent an accurate and adequate method of determining the tax deficiency, if any?

It is my opinion that the operation of the Starlight Grill as disclosed by the evidence and the stipulation comes within the provisions of the Statute and…