Arthur J. Bouchard and Irene S. Bouchard v. Commissioner of Internal Revenue

SCHNACKENBERG, Circuit Judge.

This is a petition for review of a decision of the Tax Court of the United States. The Commissioner of Internal Revenue made an additional assessment against petitioners for the calendar years of 1948 and 1949 in the total amounts of $1,720.68 and $134.28 in penalties. The court decided that certain moneys were paid by Juneau Stamping and Manufacturing Company 1 to petitioner, Arthur J. Bouchard, 2 and received by him for services rendered, and are, therefore, taxable as ordinary income.

Taxpayers are husband and wife, who did not file an income tax return for 1948…