ROMM v. COMMISSIONER OF INTERNAL REVENUE

No. 7366.

245 F.2d 730 (1957)

Joseph N. ROMM and Helen K. Romm, his wife, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fourth Circuit.

Decided May 27, 1957.


Attorney(s) appearing for the Case

Warren W. Grimes, Washington, D. C., for petitioners.

Arthur I. Gould, Attorney, Department of Justice, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., and I. Henry Kutz, Attorney, Department of Justice, Washington, D. C., on brief), for respondent.

Before SOPER and SOBELOFF, Circuit Judges, and HUTCHESON, District Judge.


SOBELOFF, Circuit Judge.

This is a petition to review the decision of the Tax Court holding the petitioner liable for income tax deficiencies and fraud penalties for the years 1942-46.

The year 1946 is open for deficiency assessment by the taxpayer's waiver of limitations, but the years 1942-45 are closed by limitations, unless the taxpayer filed fraudulent returns with the intent to evade taxes in those years. Internal...

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