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BOYETT v. COMMISSIONER OF INTERNAL REVENUE

No. 13948.

204 F.2d 205 (1953)

BOYETT et ux. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fifth Circuit.

April 21, 1953.

Attorney(s) appearing for the Case

Geo. S. Atkinson and Tom B. Rhodes, Jr., Dallas Tex., John C. Box, Jr., Jacksonville, Tex., for petitioners.

George F. Lynch, Sp. Asst. to Atty. Gen., Ellis N. Slack, Acting Asst. Atty. Gen., Mason B. Leming, Acting Chief Counsel, Bureau of Internal Revenue, Rollin H. Transue, Sp. Atty., Washington, D. C., for respondent.

Before HUTCHESON, Chief Judge, and STRUM and RIVES, Circuit Judges.

STRUM, Circuit Judge.

This matter is before us on three consolidated petitions filed by James L. Boyett and his wife, Velora Boyett, to review decisions of the Tax Court which sustained, with modifications, deficiencies in petitioners' income taxes assessed by the Commissioner, with fraud penalties, for the years 1942 through 1947.

Two fundamental questions are presented: (1) Whether or not the evidence before the Tax Court supports the Commissioner's determination...

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