Stout et al. v. Commissioner of Internal Revenue, 210 F.2d 607 (6th Cir. 1954)

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US Court of Appeals for the Sixth Circuit - 210 F.2d 607 (6th Cir. 1954) February 17, 1954

Raymond A. Fox, Detroit, Mich., for petitioner.

H. Brian Holland, Kenneth W. Gemmill, Henry Kutz, Carolyn R. Just, Washington, D. C., for respondent.

Before SIMONS, Chief Judge, and McALLISTER and MILLER, Circuit Judges.


Upon consideration of the briefs and record in the above appeal, we are of the view that the taxpayers have failed to carry the burden of proof in overcoming the Commissioner's determinations sustained by the Tax Court. The findings of the court are supported by substantial evidence and are not clearly erroneous. Wherefore, it is the view of this court that the decision of the Tax Court should be affirmed upon its findings of fact and upon its memorandum opinion filed January 30, 1954.