April 20, 1977
WILLIAM M. IVLER AND BARBARA IVLER, APPELLANTS
COMMISSIONER OF INTERNAL REVENUE, APPELLEE.
Present HONORABLE LEONARD P. MOORE, WILFRED FEINBERG, Circuit Judges.
This cause came on to be heard on the transcript of record from The Tax Court of the United States, and was argued by counsel.
ON CONSIDERATION WHEREOF, it is now hereby ordered, adjudged, and decreed that the order of said The Tax Court of the United States be and it hereby is affirmed. There is not present here the necessary "strong proof" that the contract dated November 30, 1965 did not reflect the substance of the agreement between appellant William M. Ivler and Gevyn Construction Corp. We agree with the opinion of Judge Fay, filed July 19, 1976, that "The record complied herein hardly elucidates the terms of the agreement pursuant to which" appellant allegedly "acquired" rights to "an equity interest in Gevyn."
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