Court of Appeals for the Fifth Circuit August 1, 1950, 13075_1 (Carmack Et Ux. v. Commissioner of Internal Revenue)

McCORD, Circuit Judge.

This appeal involves an alleged deficiency in Federal income tax for the year 1945, plus a five per cent negligence penalty for failure to report the entire amount of taxable income received.

The principal question confronting us for determination is whether the Tax Court properly found that taxpayer and his wife understated their gross income by $33,320.