WALET v. COMMISSIONER OF INTERNAL REVENUE

No. 17812.

272 F.2d 694 (1959)

Eugene H. WALET, Jr. and Celia R. Walet, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

December 10, 1959.


Attorney(s) appearing for the Case

Sidney W. Provensal, Jr., New Orleans, La., for petitioners.

John J. Pajak, Lee A. Jackson, Robert N. Anderson, Dept. of Justice, Washington, D. C., Charles K. Rice, Asst. Atty. Gen., John M. Morawski, Sp. Atty., I.R.S., Arch M. Cantrall, Chief Counsel, I.R.S., Washington, D. C., Howard A. Heffron, Acting Asst. Atty. Gen., for respondent.

Before TUTTLE, BROWN and WISDOM, Circuit Judges.


PER CURIAM.

This petition to review the decision of the Tax Court presents only questions of fact. We need not pass upon that Court's doubts whether the activities of the petitioner in pursuing his own oil and gas interests were sufficient to constitute a business carried on by him because we must conclude that the Tax Court's finding that there was insufficient proof that the expenditures claimed by the taxpayer, if made at all, were made for any other than personal...

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