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SIMON v. COMMISSIONER OF INTERNAL REVENUE

Nos. 15752-15755.

248 F.2d 869 (1957)

Sam SIMON, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Albert SIMON, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Clara SIMON, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Melvin SIMON, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Eighth Circuit.

October 29, 1957.

Attorney(s) appearing for the Case

Llewellyn A. Luce, Washington, D. C. (Walter H. Maloney, Washington, D. C., and Kenneth K. Simon, Kansas City, Mo., on the brief), for petitioners.

Louise Foster, Attorney, Department of Justice, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., and John N. Stull, Robert N. Anderson, and S. Dee Hanson, Attorneys, Department of Justice, Washington, D. C., on the brief), for respondent.

Before SANBORN, WOODROUGH, and VAN OOSTERHOUT, Circuit Judges.

VAN OOSTERHOUT, Circuit Judge.

Sam Simon, his wife, Clara, and his sons, Albert and Melvin Simon, hereinafter usually called taxpayers, have petitioned the court to review the decisions of the Tax Court determining substantial deficiencies in their individual income tax for the years 1942 to 1945, inclusive, and statutory additions thereto by reason of fraud and delinquency penalties. These petitions which involve common questions were consolidated in the Tax Court...

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