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YAGODA v. C. I. R.

Nos. 64-67, Dockets 28244-28247.

331 F.2d 485 (1964)

Elaine YAGODA (formerly Elaine Drechsler), Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. TRUST for the Benefit of Lena DRECHSLER, Lena Drechsler, Exec. of Estate of Gus Drechsler, Deceased Trustee, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Trust for the Benefit of Elaine Drechsler, Lena DRECHSLER, Trustee, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Lena DRECHSLER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided May 1, 1964.

Attorney(s) appearing for the Case

Bernard Weiss, New York City, for petitioners.

Richard J. Heiman, Dept. of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson and David O. Walter, Washington, D. C., on the brief), for Commissioner.

Before FRIENDLY and HAYS, Circuit Judges, and ANDERSON, District Judge.

HAYS, Circuit Judge:

Petitioners seek review of decisions of the Tax Court of the United States, 39 T.C. 170 (1962), holding (I) that the mitigation provisions of Sections 1311-1314 of the Internal Revenue Code of 1954 permit the assessment of certain deficiencies that would otherwise be barred by the statute of limitations, and (II) that petitioner Elaine Yagoda (formerly Elaine Drechsler...

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