Stout v. Commissioner of Internal Revenue

Sixth Circuit

Stout v. Commissioner of Internal Revenue

210 F.2d 607

Court of Appeals for the Sixth Circuit·Decided February 17, 1954·No. 11941·Published·Cited by 3 cases

Opinion

PER CURIAM.

Upon consideration of the briefs and record in the above appeal, we are of the view that the taxpayers have failed to carry the burden of proof in overcoming the Commissioner’s determinations sustained by the Tax Court. The findings of the court are supported by substantial evidence and are not clearly erroneous. Wherefore, it is the view of this court that the decision of the Tax Court should be affirmed upon its findings of fact and upon its memorandum opinion filed January 30, 1954.

Affirmed.

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PER CURIAM.

Upon consideration of the briefs and record in the above appeal, we are of the view that the taxpayers have failed to carry the burden of proof in overcoming the Commissioner’s determinations sustained by the Tax Court. The findings of the court are supported by substantial evidence and are not clearly erroneous. Wherefore, it is the view of this court that the decision of the Tax Court should be affirmed upon its findings of fact and upon its memorandum opinion filed January 30, 1954.

Affirmed.

Stout v. Commissioner of Internal Revenue, 210 F.2d 607 (6th Cir. 1954).

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Opinion

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