Holdeen v. United States

FREDERICK van PELT BRYAN, District Judge.

Plaintiffs, Jonathan Holdeen, and his wife, bring this action against the United States to recover personal income taxes paid by them after the Internal Revenue Service determined a deficiency in tax paid for the year 1950. Plaintiff taxpayers have moved for what they call “partial summary judgment”. Although from the confusing papers submitted in support of the motion it is difficult to ascertain in what respects the relief sought is “partial”, there appears to be no basis for the entry of judgment at this stage of the litigation in any respect.

The…