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HOPE v. C. I. R.

Nos. 71-1993 to 71-1995.

471 F.2d 738 (1973)

Karl and Hilda HOPE, Appellants in Nos. 71-1993, 71-1994, v. COMMISSIONER OF INTERNAL REVENUE, Appellant in No. 71-1995.

United States Court of Appeals, Third Circuit.

Decided January 9, 1973.

Attorney(s) appearing for the Case

Jules I. Whitman, Dilworth, Paxson, Kalish, Levy & Coleman, Philadelphia, Pa., for appellants in Nos. 71-1993, 71-1994 and appellees in No. 71-1995.

Elmer J. Kelsey, Department of Justice-Tax Division, Washington, D. C., for appellant in No. 71-1995 and appellees in Nos. 71-1993 and 71-1994.

Before GIBBONS and JAMES ROSEN, Circuit Judges, and LAYTON, District Judge.

OPINION OF THE COURT

GIBBONS, Circuit Judge.

The taxpayers, Karl and Hilda Hope, appeal from a decision of the United States Tax Court, 55 T.C. 1020, determining a deficiency in income tax for the taxable year 1960 in the amount of $985,459.00. The Commissioner has filed a protective appeal from the Tax Court decision determining an overpayment of $137,775.00 in the year 1961. Taxpayer has filed a cross appeal with respect...

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