Norman and Arlene Rodman, Appellants-Cross-Appellees v. Commissioner of Internal Revenue, Appellee-Cross-Appellant

MESKILL, Circuit Judge.

This appeal arises from several transactions of a joint business venture (“the joint venture”) involving Norman (“Norman”), Martin (“Martin”) and Robert (“Robert”) Rodman, Sydney Newman and Walter Ornstein as the joint venturers. After the Commissioner of Internal Revenue (“Commissioner”) had asserted deficiencies and penalties against Norman and Arlene Rod-man, Martin and Phyllis Rodman, and the Estate of Sydney Newman and the decedent’s wife, Dorothy, for the years 1956, 1957, and 1959 through 1962, and against Robert and Gertrude Rodman for the years 1956, 1957, 1960…