Cleveland Chair Co. v. United States

This contract case, before the court on the parties’ cross-motions for summary judgment, arose out of a tax dispute litigated in the Tax Court in the mid-1960’s, over alleged tax deficiencies said to be owing from the early 1940’s. After obtaining an adverse decision from the Tax Court in 1964, Jackson v. Commissioner, 23 T.C.M. (CCH) 2022, plaintiffs decided to appeal the ruling to the United States Court of Appeals for the Sixth Circuit. In order to do so, *362and yet stay assessment and collection of the tax deficiency determined by the Tax Court, it was necessary for plaintiffs to post an…