Julius Mendelson and Pearl Mendelson, His Wife v. Commissioner of Internal Revenue

MAJOR, Circuit Judge.

This case is here on petition for review of a decision of the Tax Court sustaining in part deficiencies • determined by respondent in income taxes due from the petitioners for the taxable years 1957 and 1958. Petitioners as husband and wife filed joint returns for those years. The failure to report income concerns only the wife, Pearl Mendelson, who will be referred to as the petitioner or taxpayer.

Respondent determined a deficiency of $638.43 for the year 1957, and an additional tax for negligence in the amount of $31.92, and a deficiency of $870.24 for the year 1958,…