Richard RUBIN and Helene Rubin, Petitioners-Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
United States Court of Appeals, Second Circuit.https://leagle.com/images/logo.png
Argued February 10, 1970.
Decided June 30, 1970.
Attorney(s) appearing for the Case
Martin D. Ginsburg, New York City (Weil, Gotshal & Manges, Martin B. Amdur and Lawrence R. Dittelman, New York City, of counsel), for petitioners-appellants.
Stuart A. Smith, Atty., Dept. of Justice, Washington, D. C. (Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson, and Harry Baum, Attys., Dept. of Justice, Washington, D. C., of counsel), for respondent-appellee.
Before LUMBARD, Chief Judge, and FRIENDLY, Circuit Judge.
United States Court of Appeals, Second Circuit.
FRIENDLY, Circuit Judge:
The Tax Court here sustained, 51 T.C. 251, a finding by the Commissioner of deficiencies in the reported income of Richard Rubin (sometimes hereafter "the taxpayer" or "the petitioner") for 1960 and 1961. The deficiencies resulted from concluding that amounts paid by Dorman Mills, Inc. for management services, rendered by Rubin, to Park International, Inc., a corporation in which he was the controlling stockholder...
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