Court of Appeals for the Fifth Circuit January 3, 1977, 76-2360 (Casper W. Marsellus v. Commissioner of Internal Revenue)

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TJOFLAT, Circuit Judge:

In this appeal, Casper W. Marsellus questions a Tax Court decision assessing against him the 50% penalty for civil fraud under section 6653(b) of the 1954 Internal Revenue Code.

1

In the proceedings below, the Tax Court determined that, for the period of 1960 through 1970, Marsellus had aggregated a basic tax deficiency of $221,712.58.