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UNITED STATES v. ROSS

No. 85, Docket 30612.

368 F.2d 455 (1966)

UNITED STATES of America, Plaintiff-Appellee, v. Leon I. ROSS, Defendant-Appellant, and Ross & Company, Ltd., and Central Trading, Inc., Defendants.

United States Court of Appeals Second Circuit.

Decided November 14, 1966.

Attorney(s) appearing for the Case

Irwin B. Robins, New York City (Robert M. Morgenthau, U. S. Atty., for the S. D. of New York, Grant B. Hering, Asst. U. S. Atty., and Harold C. Wilkenfeld, Atty., Dept. of Justice, on the brief), for appellee.

Frank R. Cohen, New York City (Farber, Cohen & Diamond, New York City, on the brief), for appellants.

Before WATERMAN, HAYS and ANDERSON, Circuit Judges.

HAYS, Circuit Judge:

This is an appeal from a judgment in favor of the United States in an action to recover income taxes owed by appellant for the years 1956-1959 on account of undistributed foreign personal holding company income realized by two foreign personal holding companies of which he was a shareholder. We affirm the determination of the lower court.

Section 551 of the Internal Revenue Code of 1954

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