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HOWELL v. COMMISSIONER OF INTERNAL REVENUE

No. 10811.

175 F.2d 240 (1949)

HOWELL v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Sixth Circuit.

June 15, 1949.

Attorney(s) appearing for the Case

Robert H. Trenkamp, Cleveland, Ohio (John H. Ritter, Cleveland, Ohio, on brief; Miller & Hornbeck, Cleveland, Ohio, of counsel), for petitioner.

Irving I. Axelrad, Washington, D. C. (Theron Lamar Caudle, Ellis N. Slack, Melva M. Graney, Washington, D. C., on brief), for respondent.

Before HICKS, Chief Judge, and ALLEN and MARTIN, Circuit Judges.

PER CURIAM.

The principal question presented by this petition to review is whether the assessment and collection of deficiencies in income taxes for the years 1940, 1941, and 1942 are barred as to petitioner by the three-year limitation of § 275(a), Int.Rev.Code, 26 U.S.C.A. § 275(a). Petitioner is the wife of Charles J. Howell, of Cleveland, Ohio, who has heretofore been indicted, pleaded guilty, and been sentenced for filing false and fraudulent income...

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