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TANCREDI v. COMMISSIONER OF INTERNAL REVENUE

Nos. 2, 3, Dockets 22282, 22283.

218 F.2d 584 (1955)

Joseph TANCREDI, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Charles LISI, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Second Circuit.

Decided January 7, 1955.

Attorney(s) appearing for the Case

Paul J. Foley, Washington, D. C., for petitioners, John R. Foley, Washington, D. C., of counsel.

H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack and Harry Baum, Sp. Assts. to Atty. Gen., David Walters, for respondent.

Before CLARK, Chief Judge, and SWAN and MEDINA, Circuit Judges.

PER CURIAM.

Tancredi and Lisi were engaged in business as partners. Each purported to form a subpartnership with members of his family pursuant to which they would have a half interest in his interest in the Tancredi and Lisi partnership. The Tax Court held that portions of the net income of the partnership in 1944 which were reported as distributed to the wife and four children of Tancredi and to the wife and four children of Lisi constituted income to the respective...

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