Court of Appeals for the Fifth Circuit October 31, 1961, 18849_1 (Emil Kalil, Sr. v. James L. Enochs, Director of Internal Revenue)

RIVES, Circuit Judge.

The complaint filed by the four appellants seeks an order directing the District Director of Internal Revenue to issue the statutory notice of deficiency,

1

often referred to as the “90-day letter,” for each of the taxable years 1950 through 1955, to two of the plaintiffs, Emil Kalil, Sr., and his wife, Dolly Kalil, hereinafter referred to as the “taxpayers.