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MARCELLO v. C. I. R.

No. 23154.

380 F.2d 509 (1967)

Peter J. and Penny V. MARCELLO, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

Rehearing Denied August 29, 1967.

Attorney(s) appearing for the Case

deQuincy V. Sutton, Meridian, Miss., for petitioners.

Mitchell Rogovin, Asst. Atty. Gen., Richard M. Roberts, Acting Asst. Atty. Gen., Lee A. Jackson, David O. Walter, Donald W. Williamson, Jr., Attys., Dept. of Justice, Lester Uretz, Chief Counsel, IRS, Glen Hardy, Atty., IRS, Washington, D.C., for respondent.

Before RIVES, COLEMAN and GODBOLD, Circuit Judges.

RIVES, Circuit Judge.

The taxpayers seek review of decisions by the Tax Court holding them liable for deficiencies in income tax for the year 1959 and negligence penalties for the years 1958 and 1959. We affirm.

I. 1958.

Peter J. and Penny V. Marcello, husband and wife, filed a joint federal income tax return for the taxable year 1958. George S. and Minnie L. Valentine, parents of Penny, also filed a joint return for the taxable year of 1958. The...

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