Jay J. and Rose B. ARMES, Petitioners-Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
United States Court of Appeals, Fifth Circuit.https://leagle.com/images/logo.png
July 9, 1971.
Rehearing Denied September 30, 1971.
Attorney(s) appearing for the Case
Towner Leeper, El Paso, Tex., for petitioners-appellants.
Johnnie M. Walters, Asst. Atty. Gen., Meyer Rothwacks, Mary J. McGinn, Bennet N. Hollander, Attys., Tax Div., Dept. of Justice, K. Martin Worthy, Chief Counsel, Daniel J. Boyer, Atty., Internal Revenue Service, for respondent-appellee.
Before GOLDBERG, GODBOLD and RONEY, Circuit Judges.
United States Court of Appeals, Fifth Circuit.
GODBOLD, Circuit Judge:
Taxpayers1 appeal from a decision of the Tax Court redetermining and assessing deficiencies (and negligence penalties) for income tax for the tax years 1960-62. The Commissioner had ascertained the deficiencies by reconstructing taxpayers' income through the use of bank deposits and excess cash expenditures, and one pivotal question before the Tax Court was whether the excess reconstructed receipts represented taxable...
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