Legal Opinion
DiZenzo v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided June 28, 1965No. 392, Docket 29360PublishedCited by 2 opinions
1Opinion of the Court
LUMBARD, Chief Judge.
Patsy DiZenzo and his wife appeal from that portion of a Tax Court decision which held them liable for additional taxes on their joint returns for 1946 through 1948.1 The issues on this appeal stem from the Tax Court’s finding that Patsy DiZenzo diverted to his own use, but did not report on the appellants’ tax returns, a part of the income of Patsy Frank, Inc. (“Patsy Frank”), a corporation controlled by him and engaged in general masonry and carpentry work in Bridgeport, Connecticut. Patsy DiZenzo owned 98 per cent of its stock; the balance was owned by his wife and son.
2Cases cited14 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- James v. United StatesSupreme Court of the United States · 1961
- Commissioner v. WilcoxSupreme Court of the United States · 1946
- Federbush v. CommissionerUnited States Tax Court · 1960
- Irving S. Federbush and Sylvia C. Federbush v. Commissioner of Internal Revenue, Sylvia C. Federbush v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1963
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3Cited by2 opinions
- United States v. William M. RuffinCourt of Appeals for the Second Circuit · 1978
- Patsy F. Dizenzo, Transferee v. Commissioner of Internal Revenue, Patsy F. Dizenzo and Anna Dizenzo v. Commissioner of Internal Revenue, Patsy Frank, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965