Lehn & Fink Products Corp. v. Commissioner

Third Circuit

Lehn & Fink Products Corp. v. Commissioner

165 F.2d 207

CourtCourt of Appeals for the Third Circuit

DecidedJanuary 6, 1948

DocketNos. 9335, 9336

StatusPublished

Cited by1 cases

This text of 165 F.2d 207 (Lehn & Fink Products Corp. v. Commissioner) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third 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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Lehn & Fink Products Corp. v. Commissioner, 165 F.2d 207 (3d Cir. 1948).

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Opinion

PER CURIAM.

The question presented by the appeals at bar is whether the Tax Court’s findings of fair market value of certain property, including trade-marks, trade names, secret processes, formulas and good will of A. S. Hinds Company possessed substantial basis in the evidence, or were arbitrary or capricious. See 7 T.C.287. Examination of the record and of the briefs filed by the parties and consideration of the oral argument convince us that the conclusions of the Tax Court do find substantial ground in the evidence. As we stated in Cochran v. Commissioner, 3 Cir., 163 F.2d 153, 155, the values of properties “are purely questions of fact”. We went on to say that if there was any evidentiary basis for the Tax Court’s finding we could not substitute our own evaluation for that of the Tax Court. The appeal at bar is ruled by such cases as Dobson v. Commissioner, 320 U.S. 489, 64 S.Ct. 239, 88 L.Ed. 248, and Commissioner v. Scottish American Co., 323 U.S. 119, 65 S.Ct. 169, 89 L.Ed. 113.

Accordingly the decisions of the Tax Court will be affirmed.

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PER CURIAM.

The question presented by the appeals at bar is whether the Tax Court’s findings of fair market value of certain property, including trade-marks, trade names, secret processes, formulas and good will of A. S. Hinds Company possessed substantial basis in the evidence, or were arbitrary or capricious. See 7 T.C.287. Examination of the record and of the briefs filed by the parties and consideration of the oral argument convince us that the conclusions of the Tax Court do find substantial ground in the evidence. As we stated in Cochran v. Commissioner, 3 Cir., 163 F.2d 153, 155, the values of properties “are purely questions of fact”. We went on to say that if there was any evidentiary basis for the Tax Court’s finding we could not substitute our own evaluation for that of the Tax Court. The appeal at bar is ruled by such cases as Dobson v. Commissioner, 320 U.S. 489, 64 S.Ct. 239, 88 L.Ed. 248, and Commissioner v. Scottish American Co., 323 U.S. 119, 65 S.Ct. 169, 89 L.Ed. 113.

Accordingly the decisions of the Tax Court will be affirmed.

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165 F.2d 207, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lehn-fink-products-corp-v-commissioner-ca3-1948.

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