ARCHER v. COMMISSIONER OF INTERNAL REVENUE

No. 15523.

227 F.2d 270 (1955)

Fred M. ARCHER and Evie B. Archer, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

November 25, 1955.


Attorney(s) appearing for the Case

Edward A. White, Washington, D. C., Ewell G. Moore, Jr., Arlington, Va., Hal Lindsay, Atlanta, Ga., for petitioners.

H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Sp. Asst. to the Atty. Gen., R. P. Hartzog, Acting Chief Counsel, Rollin H. Transue, Sp. Atty., I. R. S., Washington, D. C., George F. Lynch, Sp. Asst. to Atty. Gen., for respondent.

Before HUTCHESON, Chief Judge, and BORAH and CAMERON, Circuit Judges.


CAMERON, Circuit Judge.

This petition for review raises two questions for decision by this court: first, whether the Tax Court was in error in not accepting the statements by the petitioner, Fred Archer, and by his witnesses and deponents concerning certain of his assets at the beginning of the tax period and thereby concluding that the petitioner had substantially understated his income during the years in question; and second, whether there was sufficient evidence...

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