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KIVO v. COMMISSIONER OF INTERNAL REVENUE

No. 261, Docket 24398.

243 F.2d 858 (1957)

John KIVO, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided May 3, 1957.

Attorney(s) appearing for the Case

Charles E. Scribner, New York City (Scribner & Miller), New York City for petitioner.

Charles K. Rice, Asst. Atty. Gen., Robert N. Anderson, Charles B.E. Freeman, Attys., Dept. of Justice, Washington, D.C., for respondent.

Before HINCKS, STEWART and LUMBARD, Circuit Judges.

PER CURIAM.

The Tax Court upheld the Commissioner's determination of substantial deficiencies in the petitioner's income tax for the years 1945, 1946 and 1947. The petitioner was a member of a partnership engaged in the manufacture of artificial flowers in New York City during those years, and the Tax Court's decision rests upon a finding that the petitioner's son Aaron was not a member of a sub-partnership with petitioner during the year 1945, nor a member of the...

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