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BROWNE v. C. I. R.

No. 10395.

367 F.2d 386 (1966)

Hugh BROWNE, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fourth Circuit.

Decided September 21, 1966.

Attorney(s) appearing for the Case

Robert L. Millard, El Paso, Tex., for petitioner.

Stephen H. Paley, Atty., Dept. of Justice (Richard M. Roberts, Acting Asst. Atty. Gen., Lee A. Jackson and Gilbert E. Andrews, Attys., Dept. of Justice, on brief), for respondent.

Before SOBELOFF, BOREMAN and J. SPENCER BELL, Circuit Judges.

SOBELOFF, Circuit Judge:

The Tax Court determined that petitioner, Dr. Hugh Browne, was liable for unpaid income taxes in the amount of $27,073.89, plus civil fraud penalties of $14,452.01, due to understatement of income from 1950 through 1959. Because there were no adequate records from which to determine accurately petitioner's income, the Commissioner and the Tax Court employed the net worth method to estimate income during this period. Dr. Browne does not question...

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