NATALIE SAS-JAWORSKY AND ALEXANDER SAS-JAWORSKY, PETITIONERS,
v.
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT
NATALIE SAS-JAWORSKY AND ALEXANDER SAS-JAWORSKY, PETITIONERS,
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT
379 F.2d 337
Court of Appeals for the Fifth Circuit (1967)
Positive Treatment
Cited by 2 cases
Opinion of the Court
PER CURIAM:
Petitioners seek review of companion decisions of the Tax Court sustaining deficiencies in their separate income tax returns for the year 1959. The only issue presented by this appeal is whether the Tax Court correctly concluded that a corporation, formed by Dr. Sas-Jawor-sky and two other persons for the purpose of promoting the sale of a biography of Dr. Sas-Jaworsky, was a taxable entity. If the corporation was in fact a taxable entity, the petitioners, as individuals, are not entitled to certain deductions asserted by them and the subject matter of this litigation.
The Tax Court’s determination that the corporation was a separate entity is factual in nature and may not be overturned upon review unless clearly erroneous. See Commissioner of Internal Revenue v. Duberstein, 1960, 363 U.S. 278, 290-291, 80 S.Ct. 1190, 1199-1200, 4 L.Ed.2d 1218, 1227-1228. A careful review of the record convinces us that the evidence clearly supports the finding of the Tax Court. We accordingly affirm.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
Murl W. Garrett v. Commissioner OF Internal Revenue, 411 F.2d 615 (5th Cir. 1969)
Authorities Cited
- Commissioner of Internal Revenue v. Duberstein et ux., 363 U.S. 278 (U.S. 1960)