Crowe v. Commissioner of Internal Revenue

SPARKS, Circuit Judge.

This appeal involves the assessment of additional income taxes for 1926, 1927 and 1928, against Marie E. Crowe, individually, on unreported income of her husband, Timothy J. Crowe, who died on or about August'28, 1933.

During the years involved, the husband filed joint income tax returns for himself and wife. The return for 1926 disclosed a net income of $7,210.12. Neither the 1927 nor the 1928 return disclosed any net income.

Subsequently, the Commissioner discovered unexplained bank deposits for those years in the name of the husband, strongly suggestive of unreported…