United States v. George E. Nelson

This case has been heard on the record, briefs of the parties, and oral argument. We are of the opinion that, as hereinafter modified, the Judgment of the Court below should be affirmed.

The opinion of the District Court is published at 260 F.Supp. 70. That Court held that the taxpayers did have the burden of showing the invalidity of the Commissioner’s determination of tax liability. The controlling factual question at issue, the accuracy of the adding machine tapes from which the tax was to be computed, was resolved against the Government. We find no basis for holding this to be clearly…