HUMPHREYS v. COMMISSIONER OF INTERNAL REVENUE

No. 7700.

125 F.2d 340 (1942)

HUMPHREYS v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Seventh Circuit.

Rehearing Denied February 18, 1942.


Attorney(s) appearing for the Case

Edward J. Hess and Charles P. R. Macaulay, both of Chicago, Ill., for petitioner.

Samuel O. Clark, Jr., Asst. Atty. Gen., and Michael H. Cardozo, J. P. Wenchel, J. Louis Monarch, Carlton Fox, and Joseph M. Jones, Sp. Assts. to Atty. Gen., for respondent.

Before EVANS and KERNER, Circuit Judges, and LINDLEY, District Judge.


KERNER, Circuit Judge.

Petitioner asks us to review an order of the Board of Tax Appeals sustaining a deficiency determination for the years 1930, 1931, and 1932, 25% penalty for 1930 and 50% fraud penalty for all three years, on the ground that petitioner had not included $10,000 protection payments received from dry cleaners in 1930, $5,000 received as a proprietary interest in the Drexel Cleaners in 1931, bank deposits in the name of M. L. Brunswick totaling $29...

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