Frank E. Poulter and Thelma Poulter, Charles J. Rooney and Dolores J. Rooney, Petitioners, v. Commissioner of Internal Revenue, Respondent, 397 F.2d 415 (4th Cir. 1968)

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US Court of Appeals for the Fourth Circuit - 397 F.2d 415 (4th Cir. 1968) Submitted June 19, 1968
Decided June 20, 1968

John R. Foley, Washington, D. C., on brief for petitioners.

Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, Meyer Rothwacks, and Stanley L. Ruby, Attys., Dept. of Justice, on brief for respondent.

Before HAYNSWORTH, Chief Judge, and SOBELOFF and BOREMAN, Circuit Judges.


The contentions raised by the taxpayers in their brief on appeal were fully considered by the Tax Court*  which found no merit in any of them. It is apparent that the taxpayers are laboring under a misconception as to the burden of proof. The appeal is wholly without merit, and oral argument would be fruitless.

The decision of the Tax Court is affirmed.



Poulter v. Commissioner, T.C. Memo. 1967-220