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UNITED STATES v. BOTTENFIELD

No. 19163.

442 F.2d 1007 (1971)

UNITED STATES of America v. William M. BOTTENFIELD, Appellant, and Evelyn G. Bottenfield, Frankstown Land Development Company, Inc.

United States Court of Appeals, Third Circuit.

Decided April 30, 1971.

Attorney(s) appearing for the Case

William M. Bottenfield pro se.

Issie L. Jenkins, Dept. of Justice, Tax Division, Washington, D. C. (Johnnie M. Walters, Asst. Atty. Gen., Meyer Rothwacks, Gilbert E. Andrews, Attys., Tax Division, Dept. of Justice, Washington, D. C., Richard L. Thornburgh, U. S. Atty., on the brief) for appellee.

Before SEITZ, ALDISERT and ROSENN, Circuit Judges.

OPINION OF THE COURT

PER CURIAM:

More than ten years ago, on February 20, 1961, the Tax Court determined deficiencies in federal income taxes, together with penalties, against one or both of the taxpayers for the taxable years 1947-1950. Bottenfield v. Commissioner, T.C.M. 1335 (1961). No appeal was taken and these decisions therefore became final. 26 U.S.C. § 7481(a) (1) (Supp. 1971). Assessments for the amounts determined to be due were made on July...

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