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BORGE v. C. I. R.

Nos. 15, 16, Dockets 31903, 31904.

405 F.2d 673 (1968)

Victor BORGE, Sanna Borge, and Danica Enterprises, Inc., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided December 17, 1968.

Attorney(s) appearing for the Case

Milton Young, New York City (Stephen S. Ziegler and Robert D. Howard, New York City, on the brief), for petitioners.

Louis M. Kauder, Atty., Dept. of Justice (Mitchell Rogovin, Asst. Atty. Gen., and Lee A. Jackson and Harry Baum, Attys., Dept. of Justice, on the brief), for respondent.

Before SMITH, KAUFMAN and HAYS, Circuit Judges.

HAYS, Circuit Judge:

Petitioners seek review of a decision of the Tax Court sustaining the Commissioner's determination of deficiencies in their income tax payments for the years 1958 through 1962, inclusive. The Tax Court upheld both the Commissioner's allocation to Borge1 under Section 482 of the Internal Revenue Code of 1954, 26 U.S.C. § 482 (1964), of a portion of the compensation received by Danica Enterprises, Inc., Borge's...

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