John Robinson v. Commissioner of Internal Revenue

Ninth Circuit

John Robinson v. Commissioner of Internal Revenue

422 F.2d 873

Court of Appeals for the Ninth Circuit·Decided March 30, 1970·No. 24229_1·Published·Cited by 29 cases

Opinion

PER CURIAM:

This appeal presents issues that are largely factual. We affirm the decision of the Tax Court generally (51 T.C. 520) subject to the next paragraph below. As to the validity of Treasury Regulation 1.274-5(c) (2), see Sanford v. Commissioner, 412 F.2d 201, 202 (2d Cir. 1969), cert. denied, 396 U.S. 841, 90 S.Ct. 104, 24 L.Ed.2d 92.

The decision of the Tax Court is vacated and the matter is remanded to it solely for a recomputation of appellant’s deficiency in view of appellee’s concession (Appellee’s Brief, p. 35, n. 14) that certain expenses were inadvertently overlooked in computing appellant’s household expenses for the years 1961 and 1962.

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PER CURIAM:

This appeal presents issues that are largely factual. We affirm the decision of the Tax Court generally (51 T.C. 520) subject to the next paragraph below. As to the validity of Treasury Regulation 1.274-5(c) (2), see Sanford v. Commissioner, 412 F.2d 201, 202 (2d Cir. 1969), cert. denied, 396 U.S. 841, 90 S.Ct. 104, 24 L.Ed.2d 92.

The decision of the Tax Court is vacated and the matter is remanded to it solely for a recomputation of appellant’s deficiency in view of appellee’s concession (Appellee’s Brief, p. 35, n. 14) that certain expenses were inadvertently overlooked in computing appellant’s household expenses for the years 1961 and 1962.

John Robinson v. Commissioner of Internal Revenue, 422 F.2d 873 (9th Cir. 1970).

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Opinion

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