HARRY G. GIANAKON AND HELEN L. GIANAKON, PETITIONERS,
v.
COMMISSIONER OF INTERNAL, REVENUE, RESPONDENT

3d Cir. | 1966-04-06
No. 15637
358 F.2d 731 United States Court of Appeals for the Third Circuit (1966) Positive Treatment
Cited by 2 cases

Opinion of the Court
PER CURIAM.

[*732] PER CURIAM.

This matter is before this Court on a petition to review a decision of the Tax Court in which it was held that certain expenditures for educational purposes were not deductible as ordinary and necessary business expenses under § 162 (a) of the Internal Revenue Code of 1954, 26 U.S.C.A. § 162(a) and § 1.162-5(b) of the Treasury Regulations, 26 C.F.R., § 1.162-5. The only question for our decision is whether there exists in the record an adequate evidentiary basis for the decision. Cleveland v. C.I.R., 335 F. 2d 473 (3rd Cir. 1964) and the cases therein cited. Upon an examination of the record we are convinced that the Tax Court’s findings of fact are supported by substantial evidence and its conclusion is in accord with the law.

The decision of the Tax Court will be affirmed.


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