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Gianakon v. Commissioner of Internal Revenue

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT


decided: April 6, 1966.

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

Smith and Freedman, Circuit Judges, and Miller, District Judge.

Author: 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.

19660406

© 1998 VersusLaw Inc.



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