Roy G. Andersen and Nancy R. Andersen v. Commissioner of Internal Revenue

Ninth Circuit

Roy G. Andersen and Nancy R. Andersen v. Commissioner of Internal Revenue

341 F.2d 584, 15 A.F.T.R.2d (RIA) 415

Court of Appeals for the Ninth Circuit·Decided February 18, 1965·No. 19502_1·Published·Cited by 4 cases

Opinion

PER CURIAM.

The question is whether the findings of the Tax Court are clearly erroneous. We do not find them so.

Taxpayers assert that the Commissioner in the stipulation of facts prior to trial had stipulated that every statement in the attached exhibits was true. We do not so read the stipulation.

Taxpayers assert that the Commissioner, in opening statement, had so limited the issues as to preclude the Tax Court from deciding in this fashion. We do not so construe the statement when read in its entirety.

Judgment affirmed.

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PER CURIAM.

The question is whether the findings of the Tax Court are clearly erroneous. We do not find them so.

Taxpayers assert that the Commissioner in the stipulation of facts prior to trial had stipulated that every statement in the attached exhibits was true. We do not so read the stipulation.

Taxpayers assert that the Commissioner, in opening statement, had so limited the issues as to preclude the Tax Court from deciding in this fashion. We do not so construe the statement when read in its entirety.

Judgment affirmed.

Roy G. Andersen and Nancy R. Andersen v. Commissioner of Internal Revenue, 341 F.2d 584, 15 A.F.T.R.2d (RIA) 415 (9th Cir. 1965).

Pincite

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Opinion

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