ADLER v. C.I.R.

No. 19190.

422 F.2d 63 (1970)

Abe B. and Leona M. ADLER, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

February 20, 1970.


Attorney(s) appearing for the Case

James C. Herndon, Akron, Ohio, for petitioners-appellants.

Stephen H. Hutzelman, Dept. of Justice, Washington, D. C., for respondent-appellee; Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson, Elmer J. Kelsey, Attys., Dept. of Justice, Washington, D. C., on the brief.

Before EDWARDS and CELEBREZZE, Circuit Judges, and HOGAN, District Judge.


HOGAN, District Judge.

This is an appeal by Abe and Leona Adler from that portion of a judgment which was entered on a conclusory finding of fact that "at least a part of the deficiency or underpayment of tax by the Adlers for each of the years 1950 through 1958 was due to fraud with intent to evade tax, and each of their federal income tax returns for those years was a false and fraudulent return with intent to evade tax."

The sole question is whether that...

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