BOREMAN, Circuit Judge.
John Gatling, petitioner taxpayer, seeks review of a decision of the Tax Court determining deficiencies in his income taxes for the years 1946 through 1949, penalties for fraudulently understating his income for the years 1947, 1948 and 1949 and for failure to file a tax return for 1946.
In the absence of adequate books and records, the Commissioner of Internal Revenue used the "net worth" method of determining...
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