Rose v. Commissioner of Internal Revenue

Ninth Circuit

Rose v. Commissioner of Internal Revenue

188 F.2d 355

Court of Appeals for the Ninth Circuit·Decided May 17, 1951·No. 12539_1·Published

Opinion

PER CURIAM.

Petitioners here seek a review of decisions of the Tax Court which determined deficiencies in their federal income taxes, declared value excess-profits taxes, and excess profits taxes for the years 1938 to 1941 inclusive, and which sustained fraud and negligence penalties asserted by the respondent Commissioner.

The matters raised by the briefs and upon the oral argument present nothing but questions of fact. It is sufficient to say that our examination of the record ¡convinces us that the findings of the Tax,Court, including the findings of fraud and negligence, are supported by the evidence. Accordingly the decisions of the Tax Court are affirmed.

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PER CURIAM.

Petitioners here seek a review of decisions of the Tax Court which determined deficiencies in their federal income taxes, declared value excess-profits taxes, and excess profits taxes for the years 1938 to 1941 inclusive, and which sustained fraud and negligence penalties asserted by the respondent Commissioner.

The matters raised by the briefs and upon the oral argument present nothing but questions of fact. It is sufficient to say that our examination of the record ¡convinces us that the findings of the Tax,Court, including the findings of fraud and negligence, are supported by the evidence. Accordingly the decisions of the Tax Court are affirmed.

Rose v. Commissioner of Internal Revenue, 188 F.2d 355 (9th Cir. 1951).

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