Commissioner v. Uniacke

SWAN, Circuit Judge.

Pursuant to section 51(b) (2) of the Revenue Act of 1936, 49 Stat. 1670, 26 U.S. C.A. Int.Rev.Acts, page 844, Mary Lewis Hague and her husband filed a joint income tax return for the year 1936. The joint return was executed by the husband, and Mrs. Hague took no part in its preparation except to furnish information concerning her own income^and expenses. On March 14, 1940 the Commissioner gave notice by letter addressed to both Mr. and Mrs. Hague that he had determined a deficiency in “your income tax liability” in the sum of more than $200,000. The notice stated that the…