John Robinson v. Commissioner of Internal Revenue

This appeal presents issues that are largely factual. We affirm the decision of the Tax Court generally (51 T.C. 520) subject to the next paragraph below. As to the validity of Treasury Regulation 1.274-5(c) (2), see Sanford v. Commissioner, 412 F.2d 201, 202 (2d Cir. 1969), cert. denied, 396 U.S. 841, 90 S.Ct. 104, 24 L.Ed.2d 92.

The decision of the Tax Court is vacated and the matter is remanded to it solely for a recomputation of appellant’s deficiency in view of appellee’s concession (Appellee’s Brief, p. 35, n. 14) that certain expenses were inadvertently overlooked in computing…