William A. George v. Commissioner of Internal Revenue

ALDRICH, Circuit Judge.

This is a petition to review a decision of the Tax Court determining deficiencies in the taxpayer’s individual income returns for the years 1950-54 inclusive and assessing penalties for fraud. The original assessment, and the Tax Court decision, were both reached by an application of the net worth method. The deficiency determined by the Commissioner was based upon an asserted total understatement of adjusted gross income of $148,-973. The Tax Court, after trial, reduced this amount to $47,426, and as to one of the years found an income deficiency of only $1,412. The…