PICKETT, Circuit Judge.
This is a petition to review a judgment of the Tax Court sustaining the action of the Commissioner of Internal Revenue in assessing income tax deficiencies and 50 per centum fraud penalties for the years 1941 to 1944 inclusive. The petitioners, who filed joint income tax returns, have conceded the correctness of deficiencies and paid the same. The sole question for decision here is whether, considering the record as a whole, there is substantial...
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