Charles A. Diffendall v. Comm'r of Internal Revenue, 240 F.2d 836 (4th Cir. 1956). · Go Syfert
Charles A. Diffendall v. Comm'r of Internal Revenue, 240 F.2d 836 (4th Cir. 1956). Cases Citing This Book View Copy Cite
1 citation event across 1 distinct court.
Strongest positive: Hugh Browne v. Commissioner of Internal Revenue (ca4, 1966-09-21)
Top citers, strongest first. 1 distinct citer. How cited ↗
cited Cited "see" Hugh Browne v. Commissioner of Internal Revenue
4th Cir. · 1966 · signal: see · confidence high
See Diffendall v. Commissioner, 240 F.2d 836 (4th Cir. 1956); Romm v. Commissioner, supra. Affirmed. 1 .
Retrieving the full opinion text from the archive…
Charles A. DIFFENDALL, Petitioner,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
7203.
Court of Appeals for the Fourth Circuit.
Jul 17, 1956.
240 F.2d 836
R. Carleton Sharretts, Jr., Baltimore, Md. (C. Gordon Haines, Baltimore, Md., and John G. Turnbull, Towson, Md., on brief), for petitioner., Grant W. Wiprud, Attorney, Department of Justice, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson and Robert N. Anderson, Attorneys, Department of Justice, Washington, D. C., on brief), for respendent.
Parker, Barksdale, Bryan.
Cited by 1 opinion  |  Published
PER CURIAM.

This is a petition to review a decision of the Tax Court which imposed deficiency assessments of income tax and fraud penalties for the tax years 1944, 1945 and 1946. The taxpayer kept no adequate records and tax liability was computed by the net worth and expenditures method. The facts were found and set forth in a lengthy statement of facts by the Tax Court and were carefully analyzed and discussed in a lengthy and comprehensive opinion. See T. C. Memo 1955-162. The questions raised by the petition for review relate to the amount of cash on hand at the beginning of the net worth period, the amount of cash on hand at the end of the period, expenditures made in the construction of buildings during the period, what amount was properly attributable to good will in the sale of a business, and whether the understatement of income in the tax returns for the years in question was fraudulent. All of these were questions of fact and there is no basis upon which we would be justified in holding the findings of the Tax Court as to any of them to be clearly wrong. The decision of the Tax Court is affirmed for reasons adequately stated in its memorandum opinion.

Affirmed.