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ESTATE OF STEINBERG v. C. I. R.

No. 55, Docket 30491.

367 F.2d 130 (1966)

ESTATE of Max STEINBERG, Deceased, Pearl Steinberg, Executrix and Pearl Steinberg, Individually, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided October 10, 1966.

Attorney(s) appearing for the Case

George T. Altman, Beverly Hills, Cal., for petitioners.

Mitchell Rogovin, Asst. Atty. Gen., (Meyer Rothwacks, John P. Burke, Attys., Dept. of Justice, Washington, D. C., on the brief), for respondent.

Before MOORE, FRIENDLY and KAUFMAN, Circuit Judges.

MOORE, Circuit Judge:

Max and Pearl Steinberg (Petitioners) were married in 1942. The Commissioner of Internal Revenue (Commissioner) determined deficiencies against Max for the years 1947, 1948, and 1949, when Max and Pearl filed separate returns, and against both for 1950 and 1951, when they filed a joint return. Petitioners petitioned the Tax Court for a redetermination of the deficiencies. The assessment of a deficiency for each year concerned was barred by the...

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