Harry G. Gianakon and Helen L. Gianakon v. Commissioner of Internal Rev. Enue

Third Circuit

Harry G. Gianakon and Helen L. Gianakon v. Commissioner of Internal Rev. Enue

358 F.2d 731, 17 A.F.T.R.2d (RIA) 753, 1966 U.S. App. LEXIS 6582

Court of Appeals for the Third Circuit·Decided April 6, 1966·No. 15637_1·Published·Cited by 3 cases

Opinion

*732 PER CURIAM.

This matter is before this Court on a petition to review a decision of the Tax Court in which it was held that certain expenditures for educational purposes were not deductible as ordinary and necessary business expenses under § 162 (a) of the Internal Revenue Code of 1954, 26 U.S.C.A. § 162(a) and § 1.162-5(b) of the Treasury Regulations, 26 C.F.R., § 1.162-5. The only question for our decision is whether there exists in the record an adequate evidentiary basis for the decision. Cleveland v. C.I.R., 335 F.2d 473 (3rd Cir. 1964) and the cases therein cited. Upon an examination of the record we are convinced that the Tax Court’s findings of fact are supported by substantial evidence and its conclusion is in accord with the law.

The decision of the Tax Court will be affirmed.

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*732 PER CURIAM.

This matter is before this Court on a petition to review a decision of the Tax Court in which it was held that certain expenditures for educational purposes were not deductible as ordinary and necessary business expenses under § 162 (a) of the Internal Revenue Code of 1954, 26 U.S.C.A. § 162(a) and § 1.162-5(b) of the Treasury Regulations, 26 C.F.R., § 1.162-5. The only question for our decision is whether there exists in the record an adequate evidentiary basis for the decision. Cleveland v. C.I.R., 335 F.2d 473 (3rd Cir. 1964) and the cases therein cited. Upon an examination of the record we are convinced that the Tax Court’s findings of fact are supported by substantial evidence and its conclusion is in accord with the law.

The decision of the Tax Court will be affirmed.

Harry G. Gianakon and Helen L. Gianakon v. Commissioner of Internal Rev. Enue, 358 F.2d 731, 17 A.F.T.R.2d (RIA) 753, 1966 U.S. App. LEXIS 6582 (3d Cir. 1966).

Pincite

358 F.2d 731 (Harry G. Gianakon and Helen L. Gianakon v. Commissioner of Internal Rev. Enue) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Opinion

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