Jack Ballard and Mary Ballard v. Commissioner of Internal Revenue

HEANEY, Circuit Judge.

Jack and Mary Ballard appeal from the decision of the United States Tax Court imposing various tax assessments and additions based upon omissions of gross income from Jack Ballard’s 1968 individual income tax return and from the Ballards’ 1969 and 1970 joint income tax returns. They contend that the court’s findings of tax deficiencies and fraud on the part of Jack Ballard were erroneous; that the statute of limitations barred the assessments and additions; that the court improperly applied the doctrine of collateral estoppel to establish Jack Ballard’s fraud in filing…