SANBORN, Circuit Judge.
This is an appeal from a judgment of dismissal of an action brought by the appellant for the recovery of fraud penalties assessed against him by the Commissioner of Internal Revenue.
The sole question for decision is whether there was a sufficient evidentiary basis for the determination by the District Court that the appellant taxpayer was liable for fraud penalties, under 26 U.S.C.A. § 293(b), in connection with the assessment...
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