Loyer v. Commissioner of Internal Revenue

This cause has been heard on the taxpayer’s petition to review a decision of the Tax Court of the United States and the answer of the respondent Commissioner of Internal Revenue thereto, and on the briefs and oral argument of the contending parties and the record in the cause:

From all of which it appears that the sole issue presented is a question of fact as to whether the Commissioner of Internal Revenue committed error in the determination of the fair market value of a certain secured promissory note;

And the Tax Court, upon its findings of fact, having concluded that the Commissioner was…