POLIZZI v. C. I. R.

Nos. 13584, 13585.

265 F.2d 498 (1959)

Charles A. POLIZZI and Angela Polizzi, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Charles A. POLIZZI, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

April 2, 1959.


Attorney(s) appearing for the Case

Arlene B. Steuer, Cleveland, Ohio, Michael E. Cozza, Cozza & Steuer, Cleveland, Ohio, on brief, for petitioners.

Joseph Kovner, Washington, D. C., Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, Dept. of Justice, Washington, D. C., on brief, for respondent.

Before MARTIN, Chief Judge, MILLER, Circuit Judge, and O'SULLIVAN, District Judge.


SHACKELFORD MILLER, JR., Circuit Judge.

The petitioner Charles A. Polizzi filed timely individual income tax returns for the years 1944 and 1945. He did not file a return for the year 1947. He and his wife, Angela Polizzi, filed timely joint returns for the years 1949 and 1950. In a review of deficiencies determined by the Commissioner for each of the years referred to, the Tax Court approved deficiencies in income tax for the years 1944, 1945, 1947, 1949 and 1950...

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