DAVIS v. COMMISSIONER OF INTERNAL REVENUE

No. 4060.

184 F.2d 86 (1950)

DAVIS et ux. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Tenth Circuit.

August 9, 1950.


Attorney(s) appearing for the Case

Harold N. Rogers, Minneapolis, Minn. (P. J. Coffey, Minneapolis, Minn., on the brief), for petitioners.

L. W. Post, Washington, D. C. (Theron Lamar Caudle, Assistant Attorney General, Ellis N. Slack and S. Dee Hanson, Special Assistants to the Attorney General, on the brief), for respondent.

Before PHILLIPS, Chief Judge, and MURRAH and PICKETT, Circuit Judges.


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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