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WEBB v. C. I. R.

No. 24112.

394 F.2d 366 (1968)

Bolen WEBB and Cornelia Webb, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals Fifth Circuit.

April 23, 1968.

Attorney(s) appearing for the Case

Robert L. Blumenthal, Jack Gray Johnson, John Andrew Martin, Robert L. Blumenthal, Carrington, Johnson & Stephens, Dallas, Tex., for appellants.

Lester R. Uretz, Chief Counsel, I.R.S., Eugene F. Colella, Atty., I.R.S., Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, Joseph M. Howard, Lawrence B. Silver, Jonathan Cohen, Attys., Dept. of Justice, Washington, D. C., for appellee.

Before RIVES, GOLDBERG and AINSWORTH, Circuit Judges.

GOLDBERG, Circuit Judge:

We have for review a two-pronged decision of the Tax Court. Bolen Webb and Cornelia Webb, T.C. Memo. 1966-81 (April 20, 1966). One prong relates to deficiencies in reporting income tax liability, and the other relates to their sometimes consort, the 50% fraud penalty. The taxpayers, Bolen Webb and his wife Cornelia Webb (hereinafter Webb), seek our disavowal of the Tax Court's findings and conclusions...

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