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FERRIS v. C. I. R.

Nos. 277, 278, Dockets 27898-27899.

317 F.2d 333 (1963)

Louis J. FERRIS and Jean H. Ferris, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Louis J. FERRIS, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided May 20, 1963.

Attorney(s) appearing for the Case

George B. Lourie, Arnold R. Cutler, Daniel D. Levenson, Boston, Mass., for petitioners.

Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Meyer Rothwacks, J. Edward Shillingburg, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before WATERMAN and KAUFMAN, Circuit Judges, and WEINFELD, District Judge.

PER CURIAM.

Petitioners seek review of a decision of the Tax Court assessing deficiencies in income taxes and additions to tax for the years 1944 through 1955. Utilizing stipulated figures, except for opening cash on hand, the Commissioner determined, by the net worth method, that petitioners' unreported adjusted gross income for the years in question totaled $126,073.08. The primary issue in dispute was whether the Commissioner's opening net worth computation correctly...

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