Resorts International, Inc., Petitioner-Appellant-Cross-Appellee v. Commissioner of Internal Revenue, Respondent-Appellee-Cross-Appellant

TUTTLE, Circuit Judge.

This tax case involves four separate sets of transactions entered into by the taxpayer, Resorts International, during the tax years 1962 through 1965. The Commissioner assessed deficiencies totalling $124,924 for these years, in response to which the taxpayer filed a petition in the Tax Court for a redetermination of the deficiency. The Tax Court upheld three of the four deficiencies assessed by the Commissioner. 60 T.C. 778. The taxpayer filed this appeal, and the Commissioner cross-appealed. In our view, the Commissioner was correct as to all four deficiencies, and…