Chris D. Stoltzfus and Irma H. Stoltzfus v. United States

OPINION OF THE COURT

SEITZ, Circuit Judge.

This is an appeal from a judgment of the district court denying appellant’s (“taxpayer”) 1 request for a refund of civil fraud penalties imposed for the taxable year 1954 pursuant to Section 6653 (b) of the Interna] Revenue Code of 1954, 26 U.S.C.A. § 6653(b). The district court, sitting without a jury, determined that the government had sustained its burden of proving fraud and denied taxpayers the relief requested. 2 264 F.Supp. 824 (E.D.Pa.1967). 3

We briefly narrate pertinent portions of the evidence as stipulated by the parties or adduced by the…