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DOUGE v. C.I.R.

No. 466, Docket 88-4131.

899 F.2d 164 (1990)

Claude DOUGE and Jacqueline Douge, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided March 26, 1990.

Attorney(s) appearing for the Case

Louis F. Brush & Associates, Mineola, N.Y., submitted brief, for petitioners-appellants.

Gary R. Allen, Washington, D.C. (Shirley D. Peterson, Asst. Atty. Gen., Gilbert S. Rothenberg, Curtis C. Pett, Attys., Tax Div., Dept. of Justice, Washington, D.C., of counsel), submitted brief, for appellee.

Before OAKES, Chief Judge, CARDAMONE, Circuit Judge, and POLLACK, District Judge.

CARDAMONE, Circuit Judge:

We consider on this appeal a tax court's enforcement of a tax deficiency found by the Commissioner, and the addition of a penalty to the tax for fraud, based on its finding of a taxpayer's intentional wrongdoing. When citizens engage in the somewhat depressing annual spring rite of preparing and filing their tax returns, they may believe, with Justice Holmes, that "[t]axes are what we pay for civilized...

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