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DOWELL v. C. I. R.

No. 78-1341.

614 F.2d 1263 (1980)

Alfonzo L. DOWELL and Vivian T. Dowell, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Tenth Circuit.

Decided February 11, 1980.

Attorney(s) appearing for the Case

Stephen Jones of Jones & Gungoll, Enid, Okl. (Julius M. Greisman and Nancy S. Abramowitz of Arnold & Porter, Washington, D. C., with him on the briefs), for appellants.

Richard Farber, Dept. of Justice, Washington, D. C. (M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews and Daniel F. Ross, Attys., Tax Division, Dept. of Justice, Washington, D. C., with him on the brief), for appellee.

Before SETH, Chief Judge, HOLLOWAY, Circuit Judge, and BROWN, District Judge.

SETH, Chief Judge.

This is an appeal from a ruling of the United States Tax Court against appellants. Dowell v. Commissioner, 68 T.C. 646. The facts are undisputed. Taxpayers filed fraudulent income tax returns for calendar years 1963, 1964, 1965, and 1966. On September 13, 1968, taxpayers filed nonfraudulent amended returns for 1965 and 1966, and on November 25, 1968 they filed nonfraudulent amended returns for 1963 and 1964...

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