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LEONHART v. C. I. R.

No. 13122.

414 F.2d 749 (1969)

William H. LEONHART and Martha C. Leonhart, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals Fourth Circuit.

Decided August 25, 1969.

Attorney(s) appearing for the Case

David B. Rudow, Baltimore, Md. (Harry Adelberg, Baltimore, Md., on brief), for petitioners.

Issie L. Jenkins, Atty., Dept. of Justice (Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson and Harry Baum, Attys., Dept. of Justice, on brief), for respondent.

Before SOBELOFF, WINTER and CRAVEN, Circuit Judges.

PER CURIAM:

This is an appeal from a judgment of the Tax Court against the taxpayers. The Commissioner determined that the taxpayers, William H. Leonhart and Martha C. Leonhart, had understated their tax liability for the years 1960 and 1961. He assessed them for a deficiency and for the five percent penalty authorized by section 6653(a), I.R.C.1954, in cases in which the underpayment "is due to negligence or intentional disregard of rules and regulations."

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