Kahr v. Commissioner

WATERMAN, Circuit Judge:

The Estate of William Kahr, deceased, James F. Dalton, Executor, and William Kahr’s surviving wife, now Mary Zang-erle, petitioned the Tax Court for a redetermination of deficiencies in income tax and fraud additions, in the aggregate amounts of $25,575.19 and $13,803.62 respectively, assessed jointly against the estate and the wife for the taxable years 1958 and 1959. The Tax Court, 48 T.C. 929 (1967), sustained the assessed deficiencies except for the civil fraud addition assessed for the taxable year 1959. Five judges would have sustained the entire 1959 assessment,…