Harold G. Steiner and Ollie Mae Steiner v. Commissioner of Internal Revenue

KILEY, Circuit Judge.

Petitioners seek to set aside a judgment of the Tax Court, in consolidated dockets, 1 confirming the Commissioner’s deficiency assessments with interest and fraud penalties for the taxable years 1945, 1946 and 1947, totaling $304,-477.64. 2 We affirm the judgment.

Harold G. Steiner and his accountant prepared Steiner’s 1945 individual federal income tax return and in 1946 and 1947 Steiner prepared joint returns for himself and his wife. 3 Since all of the issues concern Steiner’s business affairs, we shall refer to him in this opinion as “taxpayer.”

During the taxable years…