VAN OOSTERHOUT, Circuit Judge.
Petitioners, Anthony and Bessie Marcella, are here asking for a review of the judgment of the Tax Court of the United States determining a deficiency in their 1947 income tax in the amount of $8,039.08 and a 50 per cent fraud penalty of $4,019.54. The deficiency determined by the Tax Court is slightly less than the amount determined by the Commissioner. Jurisdiction of this court is invoked under section 7482 of the Internal Revenue...
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