Harry K. Oliphint and Anna Leblanc Oliphint v. Commissioner of Internal Revenue

This petition for review of the decision 1 of the Tax Court, that no non-business bad debt loss resulted from taxpayer’s dealing with their puppet family corporation. It attacks, as without basis in the record, the findings and conclusions of the Tax Court: that taxpayers’ evidence fails to overcome the presumption of correctness attached to the commissioner’s determination, that the eor-poration was a fiction and puppet for tax purposes and that the so-called sale to a member of the family to establish market value was a pretense and a sham.

We cannot agree. We are, on the contrary, of the…