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RODMAN v. C. I. R.

Nos. 581, 1121, Dockets 75-4211, 75-4239.

542 F.2d 845 (1976)

Norman and Arlene RODMAN et al., Appellants-Cross-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Appellee-Cross-Appellant.

United States Court of Appeals, Second Circuit.

Decided September 17, 1976.

Attorney(s) appearing for the Case

Philip Shurmen, New York City (Paul H. Frankel, Oceanport, N.J., of counsel), for appellants-cross-appellees.

David English Carmack, Tax Div., Dept. of Justice, Washington, D.C. (Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews, Ernest J. Brown, Tax Div., Dept. of Justice, Washington, D.C., of counsel), for appellee-cross-appellant.

Before LUMBARD, WATERMAN and MESKILL, Circuit Judges.

MESKILL, Circuit Judge.

This appeal arises from several transactions of a joint business venture ("the joint venture") involving Norman ("Norman"), Martin ("Martin") and Robert ("Robert") Rodman, Sydney Newman and Walter Ornstein as the joint venturers. After the Commissioner of Internal Revenue ("Commissioner") had asserted deficiencies and penalties against Norman and Arlene Rodman, Martin and Phyllis Rodman, and the Estate of Sydney Newman and the decedent's wife...

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