Eugene H. Walet, Jr. And Celia R. Walet v. Commissioner of Internal Revenue

This petition to review the decision of the Tax Court presents only questions of fact. We need not pass upon that Court’s doubts whether the activities of the petitioner in pursuing his own oil and gas interests were sufficient to constitute a business carried on by him because we must conclude that the Tax Court’s finding that there was insufficient proof that the expenditures claimed by the taxpayer, if made at all, were made for any other than personal purposes was not clearly erroneous. On this issue, as distinguished from whether there was evidence that petitioner was actually…