Visador Company, Cross-Appellee v. Commissioner of Internal Revenue, Cross-Appellant

Fifth Circuit

Visador Company, Cross-Appellee v. Commissioner of Internal Revenue, Cross-Appellant

508 F.2d 816

CourtCourt of Appeals for the Fifth Circuit

DecidedMarch 21, 1975

Docket74-1392

StatusPublished

Cited by1 cases

This text of 508 F.2d 816 (Visador Company, Cross-Appellee v. Commissioner of Internal Revenue, Cross-Appellant) 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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Visador Company, Cross-Appellee v. Commissioner of Internal Revenue, Cross-Appellant, 508 F.2d 816 (5th Cir. 1975).

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Opinion

PER CURIAM:

After hearing oral argument and carefully reading and analyzing the record and the briefs of both parties, each appealing some portion of the Tax Court’s decision, we are of the opinion that the material factual determinations are supported by the evidence and that the legal conclusions of the Tax Court are correct in all respects. 1 Accordingly, we affirm on the basis of that opinion. See Visador Co. v. Commissioner of Internal Revenue, 32 Tax Ct.Memo. 825 (1973).

1

. There is one factual error reflected in the Tax Court opinion which Visador argues led to the erroneous conclusions of that court. The Tax Court indicated that at the time of the transaction, 1961, Dwight and Willis Coff-man, the two principals here, were employees of Coffman Stair Company, which was controlled by their father and uncle. In fact, the father had died in 1958. This error was not material to the Tax Court’s decision and we are unable to agree that it has any significance in the disposition of this case.

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PER CURIAM:

After hearing oral argument and carefully reading and analyzing the record and the briefs of both parties, each appealing some portion of the Tax Court’s decision, we are of the opinion that the material factual determinations are supported by the evidence and that the legal conclusions of the Tax Court are correct in all respects. 1 Accordingly, we affirm on the basis of that opinion. See Visador Co. v. Commissioner of Internal Revenue, 32 Tax Ct.Memo. 825 (1973).

1

. There is one factual error reflected in the Tax Court opinion which Visador argues led to the erroneous conclusions of that court. The Tax Court indicated that at the time of the transaction, 1961, Dwight and Willis Coff-man, the two principals here, were employees of Coffman Stair Company, which was controlled by their father and uncle. In fact, the father had died in 1958. This error was not material to the Tax Court’s decision and we are unable to agree that it has any significance in the disposition of this case.

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