HASTIE, Circuit Judge.
The Tax Court has determined that there are deficiencies aggregating $54,532.45 in the joint income tax returns of petitioners, Anthony Agnellino and his wife Florence, for the five years from 1953 through 1957. To these deficiency assessments 50 per cent fraud penalties were added. On this appeal the taxpayers contest both the deficiency assessments and the fraud penalties.
During the taxable years Anthony Agnellino operated a motel...
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