Nash Miami Motors, Inc., and Sydney Ginsberg v. Commissioner of Internal Revenue

RIVES, Circuit Judge:

This is a petition to review the third in a trilogy of cases involving the same *637transactions wherein the United States charged that Charles and Sydney Ginsberg with their controlled enterprise fraudulently underreported taxable income. In Ginsberg v. United States, 257 F.2d 950 (5th Cir. 1958) this Court reversed a criminal conviction of Sydney Ginsberg. Prior to retrial a plea of nolo contendere was entered and that branch of the Government’s effort was concluded. In Ginsberg’s Estate v. Commissioner, 271 F.2d 511 (5th Cir. 1959) this Court affirmed the Tax Court’s…