W. A. Shaw and Grace Shaw v. Commissioner of Internal Revenue

ALLEN, Circuit Judge.

This case arises on petition to review a decision of the United States Tax Court which determined deficiencies in income tax totalling $31,932.93 and additions thereto for 50% fraud penalties to the amount'of $15,966.47 for the taxable years 1945 to 1947, inclusive, against, W. A. Shaw, and for 1949 against W. A. Shaw and his wife, Grace Shaw.

The Commissioner had determined efficiencies for the years 1941 to 1947, inclusive, as well as for 1949. Unless fraud was established by the Commissioner the assessments for the years 1941 through 1946, inclusive, were barred by the…