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SNELL ISLE, INC. v. COMMISSIONER OF INTERNAL REVENUE

No. 8279.

90 F.2d 481 (1937)

SNELL ISLE, Incorporated, v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

June 9, 1937.

Attorney(s) appearing for the Case

Geo. E. H. Goodner, of Washington, D. C., for petitioner.

Joseph M. Jones, Norman D. Keller, and Sewall Key, Sp. Assts. to Atty. Gen., Robert H. Jackson and James W. Morris, Asst. Attys. Gen., and Herman Oliphant, Gen. Counsel, Department of Treasury, and Bruce A. Low, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before FOSTER, SIBLEY, and HUTCHESON, Circuit Judges.

FOSTER, Circuit Judge.

The Commissioner of Internal Revenue determined deficiencies in income taxes of petitioner for the fiscal years ending April 30, 1926, to April 30, 1929, both inclusive, amounting to $34,894.54. Deeming the returns were fraudulent, he also assessed a penalty of 50 per cent. in addition. Petitioner appealed to the Board of Tax Appeals. The Commissioner answered, affirmatively pleading fraud in the preparation and filing of the returns. The Board...

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