Hoyt v. Commissioner of Internal Revenue

FRANK, Circuit Judge.

Whatever our own independent opinion might be, we cannot disturb a factual inference made by the Tax Court unless it is unreasonable. Accordingly we must here accept the Tax Court’s finding which, in effect, is that the taxpayer, when she executed the guaranty, had no intention of ever asserting a claim against her daughter should taxpayer be compelled to pay the broker under the guaranty. For we cannót say that such a finding as to taxpayer’s intention cannot reasonably be inferred from these facts: The taxpayer knew that the probability was that her daughter could not…