MILLER v. C. I. R.

Nos. 115, 116, Dockets 28168, 28169.

327 F.2d 846 (1964)

Katherine F. MILLER, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Joseph M. DeTOTA, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided February 13, 1964.


Attorney(s) appearing for the Case

Harris, Beach, Wilcox, Dale & Linowitz, Rochester, N. Y., for petitioners-appellants.

Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Gilbert E. Andrews, Giora Ben-Horin, Attys., Dept. of Justice, for respondent.

Before MEDINA, WATERMAN and MARSHALL, Circuit Judges.


WATERMAN, Circuit Judge.

Petitioners appeal from adverse decisions of the Tax Court entered in consolidated cases on December 7, 1962, upholding the Commissioner of Internal Revenue's assertion of federal income tax deficiencies against them for the years 1957, 1958, and 1959. 39 T.C. 505. Jurisdiction to review these Tax Court decisions is conferred upon this court by Section 7482 of the Internal Revenue Code of 1954.

Petitioners...

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