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FACTOR v. C. I. R.

No. 16326.

281 F.2d 100 (1960)

John FACTOR, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

Rehearing Denied July 27, 1960.

Attorney(s) appearing for the Case

Robert E. Sher, Washington, D. C., for petitioner; Isadore G. Alk, Washington, D. C., Jack B. Rubin, Chicago, Ill., of counsel.

Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, A. F. Prescott, Victor A. Altman, Attys., Dept. of Justice, Washington, D. C., for respondent

Before JERTBERG and MERRILL, Circuit Judges, and YANKWICH, District Judge.

YANKWICH, District Judge.

Before us is a petition filed October 22, 1958, to review1 the decision of the Tax Court entered July 24, 1958, relating to federal income taxes for the taxable years 1935 and 1936.

On August 9, 1946, the Commissioner of Internal Revenue mailed to the taxpayer notice of deficiencies in the amount of $38,315.03 for the year 1935 and $134,912.23 for the year 1936, with an added fraud penalty of fifty per...

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