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ESTATE OF BARON v. C.I.R.

No. 623, Docket 85-4072.

798 F.2d 65 (1986)

ESTATE of Sydney S. BARON, Sylvia S. Baron, Administratrix, and Sylvia S. Baron, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided August 12, 1986.

Attorney(s) appearing for the Case

Marvin E. Frankel, New York City (Steven C. Todrys, Alvin D. Knott, New York City, Kramer, Levin, Nessen, Kamin & Frankel, of counsel), for petitioners-appellants.

Glenn L. Archer, Jr., Asst. Atty. Gen., Washington, D.C. (Michael L. Paup, Ann Belanger Durney, Michael J. Roach, Attys., Tax Div., U.S. Dept. of Justice, Washington, D.C., of counsel), for respondent-appellee.

Leon C. Baker, White Plains, as amicus curiae.

Before LUMBARD, MESKILL and PIERCE, Circuit Judges.

PIERCE, Circuit Judge:

This is an appeal from a judgment of the United States Tax Court, Tannenwald, Judge, holding that taxpayers Sydney S. Baron ("Baron"), now deceased, and his wife improperly claimed certain deductions on their joint personal income tax return for the tax years 1977 and 1978 and must therefore pay $230,031 and $82,525 for those years, respectively, pursuant to a notice of deficiency issued by the Commissioner of Internal Revenue ("Commissioner...

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