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SHAHADI v. C. I. R.

Nos. 12802-12804.

266 F.2d 495 (1959)

Albert N. SHAHADI, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent (two cases). Albert N. SHAHADI, and Josephine Shahadi, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Third Circuit.

Decided April 16, 1959.

Rehearing Denied May 11, 1959.

Attorney(s) appearing for the Case

George P. Walker, Camden, N. J., Robert M. Taylor, Philadelphia, Pa., for petitioners.

Joseph Kovner, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, A. F. Prescott, Attys., Department of Justice, Washington, D. C., on the brief), for respondent.

Before McLAUGHLIN and HASTIE, Circuit Judges, and MORRILL, District Judge.

MORRILL, District Judge.

Tax deficiencies, fraud penalties and underestimation penalties were assessed against petitioner Albert N. Shahadi for the years 1944-1949 inclusive and against him and his wife, Josephine, for the year 1950. Appeals heard by the Tax Court as a consolidated group resulted in the Commissioner being sustained and the petitioners are now before us in a consolidated review after a denial by the Tax Court of their motion for reconsideration.

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