Court of Appeals for the Second Circuit February 22, 1980, Nos. 504-508, Dockets 79-4147, 79-4149, 79-4151, 79-4153, 79-4155 (Ogiony v. Commissioner)

lead-opinion

MULLIGAN, Circuit Judge:

This is an appeal from a decision of the Tax Court, Cynthia Hall, Judge, 38 T.C.M. 358 (1979). The facts, most of which were stipulated by the parties, are set forth in detail in Judge Hall’s opinion. For the purposes of this appeal, they may be summarized as follows.

Appellants1 or their wholly-owned corporations formed two partnerships, P. Santin, J. & E.