Jefferson Loan Company, Inc., a Corporation v. Charles Rogers Arundell, as Judges of the Tax Court of the United States, in Their Official Capacities

In 1951 the Tax Court determined the tax liability of appellant, a Missouri corporation, for 1947 and 1948 on the basis of a stipulation between the corporation and the Commissioner of Internal Revenue. Payment was made accordingly. It was afterwards discovered that appellant’s president had fraudulently concealed its financial condition from its stockholders and creditors, and that appellant had no taxable income for 1947 and 1948.

In 1955, after the fraud was discovered, appellant moved in the Tax Court to withdraw the stipulation and revise the court’s decision. The Tax Court denied the…