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MORIARTY v. COMMISSIONER OF INTERNAL REVENUE

No. 11672.

208 F.2d 43 (1953)

Joseph V. MORIARTY, alias Michael and/or Michel Pitcher, alias Joseph Petrick, petitioner v. COMMISSIONER OF INTERNAL REVENUE, respondent.

United States Court of Appeals District of Columbia Circuit.

Decided November 5, 1953.

Attorney(s) appearing for the Case

Mr. Murray M. Weinstein, Washington, D. C., for petitioner.

Mr. S. Dee Hanson, Sp. Asst. to Atty. Gen., with whom Mr. Ellis N. Slack, Sp. Asst. to Atty. Gen., was on the brief, for respondent.

Mr. Rollin H. Transue, Sp. Atty., Bureau of Internal Revenue, Washington, D. C., also entered an appearance for respondent.

Before EDGERTON, BAZELON and FAHY, Circuit Judges.

PER CURIAM.

The Commissioner of Internal Revenue issued a jeopardy assessment determining deficiencies against petitioner for income taxes, together with fraud and delinquency penalties, for twelve taxable years for which no returns had been filed. These deficiencies were increased by the Commissioner in an amended answer to the petitioner's petition in the Tax Court. Petitioner took the position that all of the deficiencies were arbitrary on their face and that the...

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