Solly K. Frankenstein and Julia E. Frankenstein v. Commissioner of Internal Revenue

CASTLE, Circuit Judge.

The petitioners, Solly K. Frankenstein and Julia E. Frankenstein, husband and wife reside in Fort Wayne, Indiana. Julia E. Frankenstein is made a party to this proceeding for the reason she filed joint income tax returns with her husband for the years in question. Petitioners filed a joint Federal Income Tax Return for the years 1949,1950, 1951,1952, 1953 and 1954 with the Collector of Internal Revenue at Indianapolis, Indiana. These returns were made on the basis of cash receipts and disbursements. A deficiency tax for each year was assessed. Petitioners filed a…