POPE, Circuit Judge.
Appellee Harvey sued the appellant Director to recover sums which he asserted were wrongfully assessed and collected from him as additional income taxes, penalties and interest for the calendar years 1941 through 1947. The Commissioner's assessment was made February 5, 1954. It was based upon his finding of Harvey's net worth during the period involved here. Included were penalties assessed for fraud. That there were deficiencies for the years...
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