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WOO v. COMMISSIONER OF INTERNAL REVENUE

No. 21643.

345 F.2d 532 (1965)

Gambo WOO and Marion F. Woo and Gambo Woo, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

Rehearing Denied June 29, 1965.

Attorney(s) appearing for the Case

Samuel C. Waller, Augusta, Ga., Cumming, Nixon, Eve, Waller & Capers, Augusta, Ga., of counsel, for petitioners.

Lawrence B. Silver, Atty., Dept. of Justice, Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, Sheldon S. Cohen, Chief Counsel, I. R. S., Eugene F. Collela, Atty., I. R. S., Washington, D. C., Burton Berkley, Atty., Dept. of Justice, Washington, D. C., for respondent.

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

PER CURIAM.

Gambo Woo and his wife, Marion F. Woo, the taxpayers, have petitioned this Court to review and set aside a decision of the Tax Court of the United States.1

In the absence of the taxpayers' books and records, the Commissioner used the net worth method to reconstruct the taxpayers' income. Except for two slight modifications, the Tax Court sustained the Commissioner's determination of deficiencies in income tax for each...

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