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U.S. Court of Appeals for the Second Circuit, 1964

Ralph D. Lambert and Margot Lambert, Ernest J. Henley and Barbara M. Henley, Martha Henley v. Commissioner of Internal Revenue

Ralph D. Lambert and Margot Lambert, Ernest J. Henley and Barbara M. Henley, Martha Henley v. Commissioner of Internal Revenue
U.S. Court of Appeals for the Second Circuit · Decided October 30, 1964
338 F.2d 4 (Federal Reporter, Second Series)

Ralph D. Lambert and Margot Lambert, Ernest J. Henley and Barbara M. Henley, Martha Henley v. Commissioner of Internal Revenue

Opinion

338 F.2d 4

Ralph D. LAMBERT and Margot Lambert, Ernest J. Henley and Barbara M. Henley, Martha Henley, Petitioners,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.

Nos. 79-81.

Dockets 28983-28985.

United States Court of Appeals Second Circuit.

Argued October 20, 1964.

Decided October 30, 1964.

Raymond F. Garrity, Washington, D. C. (Garrity, Ferguson & Phillipps, Carl A. Phillipps, Washington, D. C., on brief), for petitioners.

Edward B. Greensfelder, Jr., St. Louis, Mo. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson and David O. Walter, Attys., Dept. of Justice, Washington, D. C.), for respondent.

Edward Pesin, Newark, N. J., for S. Arthur Stern, filed a brief as amicus curiae.

Before FRIENDLY, KAUFMAN and ANDERSON, Circuit Judges.

PER CURIAM:

1

We affirm the judgment of the Tax Court on the opinion of Judge Fay. Although the Commissioner might well have taken a more lenient view on the facts here presented, it is plain that the petitioners did not comply with requirements on which the Commissioner was entitled to insist.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.

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