RICE v. C. I. R.

No. 18973.

295 F.2d 239 (1961)

Leo RICE and Betty Rice, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

Rehearing Denied November 17, 1961.


Attorney(s) appearing for the Case

Betty Rice, Miami, Fla., for petitioners.

Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, Washington, D. C., R. P. Hertzog, Acting Chief Counsel, I. R. S., Rollin H. Transue, Sp. Atty., I. R. S., Washington, D. C., Meyer Rothwacks, Atty., Dept. of Justice, Washington, D. C., and Donald P. Horwitz, Arlington, Va., for respondent.

Before TUTTLE, Chief Judge, and JONES and WISDOM, Circuit Judges.


PER CURIAM.

The Tax Court, by a memorandum opinion, held that the petitioners had understated their taxable income for the years 1943 to 1948, inclusive, and that the deficiencies, in part, for each of the years, were due to fraud with intent to evade tax. The petitioners bring the Tax Court's determination before us for review. The evidence sustains the fraud findings. In determining income by the net-worth basis, the Tax...

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