Scribd Logo
Upload

Welcome to Scribd!

  • Julius Godeny and Mary Godeny v. Commissioner of Internal Revenue, 339 F.2d 262, 3rd Cir. (1964)

    Uploaded by

    Scribd Government Docs
    3 views1 page
    The United States Court of Appeals for the Third Circuit affirmed the decision of the Tax Court, which determined deficiencies in the petitioners' income tax liability for the years 1956 through 1958 and upheld fraud penalties added by the Commissioner for each of those years. The petitioners sought review of the Tax Court's decision, arguing its crucial findings were clearly erroneous, but the Court of Appeals found substantial evidence in the record to support the Tax Court's findings. The Court of Appeals saw no reason to further discuss the evidence and was in full agreement with the Tax Court's opinion.

    Original Description:

    Filed: 1964-12-21 Precedential Status: Precedential Citations: 339 F.2d 262 Docket: 14895_1

    Copyright

    © Public Domain

    Available Formats

    PDF or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    Report this Document
    The United States Court of Appeals for the Third Circuit affirmed the decision of the Tax Court, which determined deficiencies in the petitioners' income tax liability for the years 1956 through 1958 and upheld fraud penalties added by the Commissioner for each of those years. The petitioners sought review of the Tax Court's decision, arguing its crucial findings were clearly erroneous, but the Court of Appeals found substantial evidence in the record to support the Tax Court's findings. The Court of Appeals saw no reason to further discuss the evidence and was in full agreement with the Tax Court's opinion.

    Copyright:

    Public Domain
    Download as PDF or read online from Scribd
    Flag for inappropriate content
    3 views1 page

    Julius Godeny and Mary Godeny v. Commissioner of Internal Revenue, 339 F.2d 262, 3rd Cir. (1964)

    Uploaded by

    Scribd Government Docs
    The United States Court of Appeals for the Third Circuit affirmed the decision of the Tax Court, which determined deficiencies in the petitioners' income tax liability for the years 1956 through 1958 and upheld fraud penalties added by the Commissioner for each of those years. The petitioners sought review of the Tax Court's decision, arguing its crucial findings were clearly erroneous, but the Court of Appeals found substantial evidence in the record to support the Tax Court's findings. The Court of Appeals saw no reason to further discuss the evidence and was in full agreement with the Tax Court's opinion.

    Copyright:

    Public Domain
    Download as PDF or read online from Scribd
    Flag for inappropriate content
    of 1

    339 F.

    2d 262

    Julius GODENY and Mary Godeny, Petitioners


    v.
    COMMISSIONER OF INTERNAL REVENUE, Respondent.
    No. 14895.

    United States Court of Appeals Third Circuit.


    Argued December 11, 1964.
    Decided December 21, 1964.

    Petition for Review of Decision of the Tax Court of the United States.
    Robert M. Taylor, Philadelphia, Pa., for petitioner.
    Jeanine Jacobs, Dept. of Justice, Tax Division, Washington, D. C., Louis
    F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, George F. Lynch,
    Attorneys, Department of Justice, Washington, D. C., for respondent.
    Before MARIS, GANEY and SMITH, Circuit Judges.
    PER CURIAM.

    The petitioners here seek review of a decision of the Tax Court determining
    deficiencies in their income tax liability for the years 1956, 1957 and 1958 and
    upholding fraud penalties added by the Commissioner for each of those years.
    The issues raised on review are purely factual, the petitioners urging us to set
    aside the crucial findings of the Tax Court as clearly erroneous. Our
    examination of the record satisfies us, however, that there is substantial
    evidence to support the findings. We see no reason to add to the discussion of
    the evidence contained in Judge Mulroney's opinion with which we are in full
    agreement.

    The decision of the Tax Court will be affirmed.

    You might also like