James L. Enochs, United States District Director of Internal Revenue for the District of Mississippi v. Kenneth Muse and Winnie Muse

JONES, Circuit Judge.

The appellees, Kenneth Muse and Winnie Muse, are husband and wife. They will be referred to in this opinion as the taxpayers. They filed within the prescribed time a joint income tax return for the year 1956 and paid the tax as shown by the return to be owing. Thereafter the District Director determined that the taxpayers had underpaid estimated tax under the provisions of Section 6654 of the Internal Revenue Code of 1954. 1 The Director made an assessment in the amount of S204.23 and demanded payment. The taxpayers brought suit seeking an injunction against the…