U.S. Court of Appeals for the Third Circuit, 1966

Harry G. Gianakon and Helen L. Gianakon v. Commissioner of Internal Rev. Enue

Harry G. Gianakon and Helen L. Gianakon v. Commissioner of Internal Rev. Enue
U.S. Court of Appeals for the Third Circuit · Decided April 6, 1966 · Smith, Freedman, Miller
358 F.2d 731; 17 A.F.T.R.2d (RIA) 753; 1966 U.S. App. LEXIS 6582 (Federal Reporter, Second Series)

Harry G. Gianakon and Helen L. Gianakon v. Commissioner of Internal Rev. Enue

Opinion

*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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