Appeal of Allen

Board of Tax Appeals

Appeal of Allen

2 B.T.A. 794

CourtUnited States Board of Tax Appeals

DecidedOctober 5, 1925

DocketDocket No. 3267

StatusPublished

Cited by1 cases

This text of 2 B.T.A. 794 (Appeal of Allen) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Appeal of Allen, 2 B.T.A. 794 (bta 1925).

Pincite

Opinion

This is an appeal from the determination of deficiencies in income and profits taxes of $4,798.81 and $568.69 for the calendar years 1919 and 1920, respectively, all of which are in controversy. The taxpayer asserts that the Commissioner erred in adjusting inventories and capital investment and in the computation of depreciation on machinery and equipment for the years in question. The parties agree that only questions of fact are involved. In the petition, counsel for the taxpayer refers to a revenue agent’s report, to the deficiency letter, and to the disputed inventories, but none of such documents was adduced in evidence. The oral testimony offered by counsel himself as a witness was for the most part incompetent and was entirely without probative value. The Board, therefore, is unable to make any findings of fact upon. which to review the determination of the Commissioner.

DECISION.

The determination of the Commissioner is approved.

ARTjndell not participating.

Free access — add to your briefcase to read the full text and ask questions with AI

This is an appeal from the determination of deficiencies in income and profits taxes of $4,798.81 and $568.69 for the calendar years 1919 and 1920, respectively, all of which are in controversy. The taxpayer asserts that the Commissioner erred in adjusting inventories and capital investment and in the computation of depreciation on machinery and equipment for the years in question. The parties agree that only questions of fact are involved. In the petition, counsel for the taxpayer refers to a revenue agent’s report, to the deficiency letter, and to the disputed inventories, but none of such documents was adduced in evidence. The oral testimony offered by counsel himself as a witness was for the most part incompetent and was entirely without probative value. The Board, therefore, is unable to make any findings of fact upon. which to review the determination of the Commissioner.

DECISION.

The determination of the Commissioner is approved.

ARTjndell not participating.

Cite This Page — Counsel Stack

Bluebook (online)

2 B.T.A. 794, Counsel Stack Legal Research, https://law.counselstack.com/opinion/appeal-of-allen-bta-1925.

Opinion

Related

Cite This Page — Counsel Stack