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SILVERMAN v. C. I. R.

No. 509, Docket 75-4162.

538 F.2d 927 (1976)

Seymour SILVERMAN et al., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided June 21, 1976.

Attorney(s) appearing for the Case

Wallace Musoff, New York City (Wagman, Cannon & Musoff, P. C., New York City, on the briefs), for petitioners-appellants.

Gilbert E. Andrews, Atty., Tax Div., Dept. of Justice, Washington, D.C. (Scott P. Crampton, Asst. Atty. Gen., Elmer J. Kelsey, Francis J. Gould, Attys., Tax Div., Dept. of Justice, Washington, D.C., on the brief), for respondent-appellee.

Before HAYS, MULLIGAN and GURFEIN, Circuit Judges.

HAYS, Circuit Judge:

Taxpayers Seymour and Helen Silverman and Jack and Frances Silverman appeal from decisions of the United States Tax Court entered May 20, 1975, pursuant to a Memorandum Opinion and Findings of Fact by Judge William H. Quealy1 filed November 6, 1974, which determined that Seymour and Helen Silverman each owed a deficiency of $43,890 in gift taxes for the year 1968 and that Jack and Frances Silverman each owed a deficiency...

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