Estate of Carl Genenwein, Deceased. Anna M. Genenwein, and Anna M. Genenwein, Individually v. Commissioner of Internal Revenue

The Commissioner determined deficiencies in income tax against petitioners, husband and wife, for the years 1944, 1945, 1947, and 1950, and added a 50% penalty for fraud and a 25% delinquency penalty under 26 U.S.C. (I.R.C.1939) § 291.

Petitioners filed no income tax returns for any year before 1950, in which year they filed a joint return. During the periods involved they kept no books nor records and respondent properly determined their taxable income under the net worth method combined with the nondeductible expenditures method, 26 U.S.C. (I.R.C.1939) § 41.

The Tax Court gave detailed and…