Pridgen v. Commissioner

Second Circuit

Pridgen v. Commissioner

434 F.2d 67

CourtCourt of Appeals for the Second Circuit

DecidedNovember 18, 1970

DocketNo. 232, Docket 35103

StatusPublished

This text of 434 F.2d 67 (Pridgen v. Commissioner) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Pridgen v. Commissioner, 434 F.2d 67 (2d Cir. 1970).

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Opinion

PER CURIAM:

We have examined with care everything submitted to us by the parties to this appeal, including the reply brief which, on October 29, 1970, we granted appellants leave to file, and we find no legal basis upon which to disturb the decision below. There was a complete failure on the part of the taxpayers to substantiate the alleged deductions. This record discloses no charge of fraud against the taxpayers nor any proof of fraud. We affirm on the findings and opinion of Judge Sterrett below. 28 T.C.M. 717 (1969). No costs.

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PER CURIAM:

We have examined with care everything submitted to us by the parties to this appeal, including the reply brief which, on October 29, 1970, we granted appellants leave to file, and we find no legal basis upon which to disturb the decision below. There was a complete failure on the part of the taxpayers to substantiate the alleged deductions. This record discloses no charge of fraud against the taxpayers nor any proof of fraud. We affirm on the findings and opinion of Judge Sterrett below. 28 T.C.M. 717 (1969). No costs.

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434 F.2d 67, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pridgen-v-commissioner-ca2-1970.

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