Natalie Sas-Jaworsky and Alexander Sas-Jaworsky v. Commissioner of Internal Revenue

Fifth Circuit

Natalie Sas-Jaworsky and Alexander Sas-Jaworsky v. Commissioner of Internal Revenue

379 F.2d 337, 19 A.F.T.R.2d (RIA) 1750, 1967 U.S. App. LEXIS 5924

CourtCourt of Appeals for the Fifth Circuit

DecidedJune 21, 1967

Docket23236_1

StatusPublished

Cited by3 cases

This text of 379 F.2d 337 (Natalie Sas-Jaworsky and Alexander Sas-Jaworsky 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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Natalie Sas-Jaworsky and Alexander Sas-Jaworsky v. Commissioner of Internal Revenue, 379 F.2d 337, 19 A.F.T.R.2d (RIA) 1750, 1967 U.S. App. LEXIS 5924 (5th Cir. 1967).

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Opinion

PER CURIAM:

Petitioners seek review of companion decisions of the Tax Court sustaining deficiencies in their separate income tax returns for the year 1959. The only issue presented by this appeal is whether the Tax Court correctly concluded that a corporation, formed by Dr. Sas-Jawor-sky and two other persons for the purpose of promoting the sale of a biography of Dr. Sas-Jaworsky, was a taxable entity. If the corporation was in fact a taxable entity, the petitioners, as individuals, are not entitled to certain deductions asserted by them and the subject matter of this litigation.

The Tax Court’s determination that the corporation was a separate entity is factual in nature and may not be overturned upon review unless clearly erroneous. See Commissioner of Internal Revenue v. Duberstein, 1960, 363 U.S. 278, 290-291, 80 S.Ct. 1190, 1199-1200, 4 L.Ed.2d 1218, 1227-1228. A careful review of the record convinces us that the evidence clearly supports the finding of the Tax Court. We accordingly affirm.

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PER CURIAM:

Petitioners seek review of companion decisions of the Tax Court sustaining deficiencies in their separate income tax returns for the year 1959. The only issue presented by this appeal is whether the Tax Court correctly concluded that a corporation, formed by Dr. Sas-Jawor-sky and two other persons for the purpose of promoting the sale of a biography of Dr. Sas-Jaworsky, was a taxable entity. If the corporation was in fact a taxable entity, the petitioners, as individuals, are not entitled to certain deductions asserted by them and the subject matter of this litigation.

The Tax Court’s determination that the corporation was a separate entity is factual in nature and may not be overturned upon review unless clearly erroneous. See Commissioner of Internal Revenue v. Duberstein, 1960, 363 U.S. 278, 290-291, 80 S.Ct. 1190, 1199-1200, 4 L.Ed.2d 1218, 1227-1228. A careful review of the record convinces us that the evidence clearly supports the finding of the Tax Court. We accordingly affirm.

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379 F.2d 337, 19 A.F.T.R.2d (RIA) 1750, 1967 U.S. App. LEXIS 5924, Counsel Stack Legal Research, https://law.counselstack.com/opinion/natalie-sas-jaworsky-and-alexander-sas-jaworsky-v-commissioner-of-internal-ca5-1967.

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