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UNITED STATES v. FEINBERG

No. 15036.

372 F.2d 352 (1965)

UNITED STATES of America v. Bernard FEINBERG, Administrator of the Estate of Joseph Saladoff, Deceased, Appellant.

United States Court of Appeals Third Circuit.

Decided September 17, 1965.

Reargued December 8, 1965.

Reargued December 8, 1966.

Decided on Rehearing January 13, 1967.

Attorney(s) appearing for the Case

Nochem S. Winnet, Fox, Rothschild, O'Brien & Frankel, Philadelphia, Pa. (William T. Tsiouris, Israel Packel, Philadelphia, Pa., on the brief), for appellant.

Morton Rothschild, Dept. of Justice, Tax Division, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, David O. Walter, Attys., Dept. of Justice, Washington, D. C., Drew J. T. O'Keefe, U. S. Atty., Sidney Salkin, Asst. U. S. Atty., on the brief), for appellee.

Before BIGGS, Chief Judge, and FORMAN and FREEDMAN, Circuit Judges.

Reargued En Banc December 8, 1966.

FORMAN, Circuit Judge.

This is an appeal from the judgment of the United States District Court for the Eastern District of Pennsylvania.1 Only a sketchy reference to the factual background of the case is required for it is amply detailed in the reported opinion of the District Court.2

The United States had assessed the late Joseph Saladoff with income tax liability...

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