J. Ungar, Inc. v. Commissioner of Internal Revenue, Jesse Ungar (Transferee) v. Commissioner of Internal Revenue

HAND, Circuit Judge.

This is a petition to review an order of the Tax Court in banco, opinion by Rice, J., 26 T.C. 331, with whose findings and conclusion we are in accord, which held that a New York corporation (which we shall call the Corporation), was liable for a deficiency of $31,957.21 for unpaid income and excess profits tax for its fiscal year, ending February 28, 1951. The only issue is as to the amount of the corporate income during the year in question. The Corporation had been doing a commission business as agent for a Spanish exporter of olives and olive oil which we shall call…