Howell v. Commissioner of Internal Revenue

The principal question presented by this petition to review is whether the assessment and collection of deficiencies in income taxes for the years 1940, 1941, and 1942 are barred as to petitioner by the three-year limitation of § 275(a), Int.Rev.Code, 26 U.S.C.A. § 275(a). Petitioner is the wife of Charles J. Howell, of Cleveland, Ohio, who has heretofore been indicted, pleaded guilty, and been sentenced for filing false and fraudulent income tax returns for the years 1939 to 1943, inclusive. The returns for 1940, 1941 and 1942 involved in the criminal proceedings against Howell are the same…