Julius Godeny and Mary Godeny v. Commissioner of Internal Revenue

Third Circuit

Julius Godeny and Mary Godeny v. Commissioner of Internal Revenue

339 F.2d 262, 15 A.F.T.R.2d (RIA) 20, 1964 U.S. App. LEXIS 3520

Court of Appeals for the Third Circuit·Decided December 21, 1964·No. 14895_1·Published·Cited by 1 cases

Opinion

PER CURIAM.

The petitioners here seek review of a decision of the Tax Court determining deficiencies in their income tax liability for the years 1956, 1957 and 1958 and upholding fraud penalties added by the Commissioner for each of those years. The issues raised on review are purely factual, the petitioners urging us to set aside the crucial findings of the Tax *263 Court as clearly erroneous. Our examination of the record satisfies us, however, that there is substantial evidence to support the findings. We see no reason to add to the discussion of the evidence contained in Judge Mulroney’s opinion with which we are in full agreement.

The decision of the Tax Court will be affirmed.

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PER CURIAM.

The petitioners here seek review of a decision of the Tax Court determining deficiencies in their income tax liability for the years 1956, 1957 and 1958 and upholding fraud penalties added by the Commissioner for each of those years. The issues raised on review are purely factual, the petitioners urging us to set aside the crucial findings of the Tax *263 Court as clearly erroneous. Our examination of the record satisfies us, however, that there is substantial evidence to support the findings. We see no reason to add to the discussion of the evidence contained in Judge Mulroney’s opinion with which we are in full agreement.

The decision of the Tax Court will be affirmed.

Julius Godeny and Mary Godeny v. Commissioner of Internal Revenue, 339 F.2d 262, 15 A.F.T.R.2d (RIA) 20, 1964 U.S. App. LEXIS 3520 (3d Cir. 1964).

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Opinion

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