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GUNN v. COMMISSIONER OF INTERNAL REVENUE

No. 15673.

247 F.2d 359 (1957)

C. C. GUNN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Eighth Circuit.

August 8, 1957.

Attorney(s) appearing for the Case

Owen C. Pearce, Fort Smith, Ark. (Bethell & Pearce, Fort Smith, Ark., and Ralph W. Robinson, Van Buren, Ark., on the brief), for petitioner.

Sheldon I. Fink, Atty., Dept. of Justice, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, Robert N. Anderson, and S. Dee Hanson, Attys., Dept. of Justice, Washington, D. C., on the brief), for respondent.

Before GARDNER, Chief Judge, JOHNSEN, Circuit Judge, and DONOVAN, District Judge.

JOHNSEN, Circuit Judge.

A decision of the Tax Court (not officially reported), which redetermined deficiencies in income taxes for the years 1942-1946 and upheld fraud penalties for the years 1942-1944, is before us for review, on petition of the taxpayer. The tax deficiencies were in the amount of $55,562.15 and the fraud penalties in the amount of $27,715.99.

The primary contention urged here is that the Tax Court erred in crediting and adopting the Commissioner...

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