Greenfeld v. Commissioner of Internal Revenue

SOPER, Circuit Judge.

This is an appeal from a judgment of the Tax Court sustaining the action of the-Commissioner of Internal Revenue in assessing income tax deficiencies and 50% fraud penalties for the years 1934 and 1935 under Section 22(a) and 293(b), respectively, of the Revenue Act of 1934, 48 Stat. 680, 26 U.S.C.A.Int.Rev.Code, §§ 22(a), 293(b). The principal points urged by the taxpayer on this appeal are that the findings of the Tax Court are not supported by substantial evidence, and that the assessments are barred by the 3-year statute of limitations prescribed in Section 275(a) of…