Harold Gradsky and Bertha Gradsky v. Commissioner of Internal Revenue

Fifth Circuit

Harold Gradsky and Bertha Gradsky v. Commissioner of Internal Revenue

452 F.2d 417, 28 A.F.T.R.2d (RIA) 6082, 1971 U.S. App. LEXIS 6769

CourtCourt of Appeals for the Fifth Circuit

DecidedDecember 3, 1971

Docket71-1031

StatusPublished

Cited by1 cases

This text of 452 F.2d 417 (Harold Gradsky and Bertha Gradsky v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Harold Gradsky and Bertha Gradsky v. Commissioner of Internal Revenue, 452 F.2d 417, 28 A.F.T.R.2d (RIA) 6082, 1971 U.S. App. LEXIS 6769 (5th Cir. 1971).

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Opinion

*418 PER CURIAM:

This appeal is from the decision of the Tax Court 1 finding in favor of the Commissioner on petitions by appellants for redetermination of income tax and additions to tax for taxable years 1958 through 1962. The only issue raised on appeal is whether Harold Gradsky received taxable income in the form of funds channelled to him from two family corporations, Fidelity Investment and Loan Associates, Inc. (taxable years 1960 and 1961) and Gulf Intercontinental Finance Corp., Ltd. (taxable year 1962), consisting in large part of purported loans.

We agree with the conclusion of the Tax Court that appellants did not carry the burden of demonstrating error in the presumptively correct determinations made by the Commissioner. The decision of the Tax Court is affirmed.

1

. 29 T.C.M. 181.

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*418 PER CURIAM:

This appeal is from the decision of the Tax Court 1 finding in favor of the Commissioner on petitions by appellants for redetermination of income tax and additions to tax for taxable years 1958 through 1962. The only issue raised on appeal is whether Harold Gradsky received taxable income in the form of funds channelled to him from two family corporations, Fidelity Investment and Loan Associates, Inc. (taxable years 1960 and 1961) and Gulf Intercontinental Finance Corp., Ltd. (taxable year 1962), consisting in large part of purported loans.

We agree with the conclusion of the Tax Court that appellants did not carry the burden of demonstrating error in the presumptively correct determinations made by the Commissioner. The decision of the Tax Court is affirmed.

1

. 29 T.C.M. 181.

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452 F.2d 417, 28 A.F.T.R.2d (RIA) 6082, 1971 U.S. App. LEXIS 6769, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harold-gradsky-and-bertha-gradsky-v-commissioner-of-internal-revenue-ca5-1971.

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