Bolen Webb and Cornelia Webb v. Commissioner of Internal Revenue

GOLDBERG, Circuit Judge:

We have for review a two-pronged decision of the Tax Court. Bolen Webb and Cornelia Webb, T. C. Memo 1966-81 (April 20, 1966). One prong relates to deficiencies in reporting income tax liability, and the other relates to their sometimes consort, the 50% fraud penalty. The taxpayers, Bolen Webb and his wife Cornelia Webb (hereinafter Webb), seek our disavowal of the Tax Court’s findings and conclusions on both prongs. We see no reason for such disavowal as to either the deficiency or the fraud and affirm.

The years during which Webb’s income is in question are 1958,…