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RASQUIN v. MUCCINI

Nos. 434-436.

72 F.2d 688 (1934)

RASQUIN v. MUCCINI. SAME v. CAPLIS (two cases).

Circuit Court of Appeals, Second Circuit.

August 10, 1934.

Attorney(s) appearing for the Case

Howard W. Ameli, U. S. Atty., of Brooklyn, N. Y. (Emanuel Bublick and Albert D. Smith, Asst. U. S. Attys., both of Brooklyn, N. Y., Henry C. Clark, of Washington, D. C., and George R. Sherriff, General Counsel, Bureau of Internal Revenue, of New York City, of counsel), for appellant.

A. H. Goodman, of New York City, for Andrew J. S. and Margaret M. Caplis.

Roe & Kramer, of New York City, for Ernest Muccini.

Before L. HAND, AUGUSTUS N. HAND, and CHASE, Circuit Judges.

CHASE, Circuit Judge.

These appeals all raise the same issues, and one opinion will suffice.

John M. Phillips, who was a resident of the Eastern district of New York, filed no income tax returns for the years 1922 to 1926, inclusive. In 1928, the collector of internal revenue for this district made an examination pursuant to section 1104 of the Revenue Act of 1926, as amended by section 618 of the Revenue Act of 1928...

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