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BAILEY v. C.I.R.

No. 136, Docket 92-4056.

993 F.2d 288 (1993)

Guy B. BAILEY, Jr., Lois M. Bailey, Bernard B. Neuman, and Miriam Neuman, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided April 20, 1993.

Attorney(s) appearing for the Case

Pierce O'Donnell, New York City (Michael Malina, Peter L. Faber, Richard A. De Sevo, Laurie Abramowitz, Kaye, Scholer, Fierman, Hays & Handler, Richard A. Levine, Carlton M. Smith, Roberts & Holland, on the brief), for petitioners-appellants.

Nancy G. Morgan, Attorney, Tax Div., Dept. of Justice, Washington, DC (James A. Bruton, Acting Assistant Attorney General, Gary R. Allen, Gilbert S. Rothenberg, Attorneys, Tax Div., Dept. of Justice, on the brief), for respondent-appellee.

Before: FEINBERG and KEARSE, Circuit Judges.

KEARSE, Circuit Judge:

Petitioners Guy B. Bailey, Jr., Lois M. Bailey, Bernard B. Neuman, and Miriam Neuman (collectively "taxpayers") appeal from final decisions of the United States Tax Court, Irene F. Scott, Judge, finding deficiencies in their income taxes for certain years during the period 1973-1976. The tax court, following a remand from this Court on taxpayers' prior appeal, Bailey v. Commissioner, 912 F.2d 44

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