FALKOFF v. C. I. R.

Nos. 78-1728, 78-1729.

604 F.2d 1045 (1979)

Milton FALKOFF and Jeannette L. Falkoff, Appellants-Cross-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Appellee-Cross-Appellant.

United States Court of Appeals, Seventh Circuit.

Decided August 30, 1979.


Attorney(s) appearing for the Case

Bryon S. Miller and Alan L. Reinstein, Chicago, Ill., for appellants-cross-appellees.

William A. Friedlander, Tax Div., Dept. of Justice, Washington, D. C., for appellee-cross-appellant.

Before PELL and WOOD, Circuit Judges, and KIRKLAND, Senior District Judge.


HARLINGTON WOOD, Jr., Circuit Judge.

The taxpayers, Milton and Jeannette Falkoff, appeal from the Tax Court's judgment against them for unpaid taxes for the calendar year 1969. The subject matter of the litigation is a complex series of financial transactions between a partnership doing business as Henry Crown and Company, Not Incorporated (hereinafter referred to as the Partnership), in which the taxpayers held a beneficial interest, Henry Crown and Company, an Illinois...

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