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PERLMAN v. COMMISSIONER OF INTERNAL REVENUE

Nos. 91, 92, Dockets 24693, 24730.

252 F.2d 890 (1958)

Leo PERLMAN and Sima Perlman, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. ESTATE of Paul BACKER, by Leo Perlman, Abraham S. Guterman, Alfred G. Baker Lewis, and Charles Backer, Executors, and Julia Backer, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals Second Circuit.

Decided March 4, 1958.

Attorney(s) appearing for the Case

Abraham S. Guterman, New York City, for petitioners-appellants.

Morton K. Rothschild, Department of Justice, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, Department of Justice, Washington, D. C., on the brief), for respondent-appellee.

Before MEDINA, WATERMAN and MOORE, Circuit Judges.

MOORE, Circuit Judge.

The petitioners, Leo Perlman and Sima Perlman, his wife, appeal from a decision of the Tax Court, 27 T.C. 755, which adjudged a deficiency of $11,072.78 in their 1950 income tax. In a similar case a 1950 income tax deficiency of $9,517.68 was found against the Estate of Paul Backer and Julia Backer, his wife. The appeals in the two cases have been consolidated.

Leo Perlman participated in 1943 in the organization...

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