TAYLOR v. C. I. R.

No. 8289.

298 F.2d 198 (1962)

John C. TAYLOR and Evelene B. Taylor, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fourth Circuit.

Decided January 4, 1962.


Attorney(s) appearing for the Case

J. Alex Neely, Jr., Anderson, S. C., for petitioners.

Karl Schmeidler, Atty., Dept. of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., and Lee A. Jackson and Robert N. Anderson, Attys., Dept. of Justice, Washington, D. C., on brief), for respondent.

Before SOPER, HAYNSWORTH, and BOREMAN, Circuit Judges.


HAYNSWORTH, Circuit Judge.

The taxpayers contest the Commissioner's recomputation of certain capital gains realized by them. In this court, they undertake to relitigate issues, largely factual, resolved against them by the Tax Court. Since the findings of the Tax Court are supported by substantial evidence and are not clearly erroneous, we necessarily affirm.

The taxpayers, husband and wife, filed a joint return in 1951. The return disclosed ordinary income...

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