Appeal of Packman

Board of Tax Appeals

Appeal of Packman

2 B.T.A. 508

CourtUnited States Board of Tax Appeals

DecidedSeptember 8, 1925

DocketDocket No. 734

StatusPublished

Cited by1 cases

This text of 2 B.T.A. 508 (Appeal of Packman) 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 Packman, 2 B.T.A. 508 (bta 1925).

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Opinion

[509]*509OPINION.

Phillips:

Taxpayer alleges that the Commissioner committed error in fixing the value of the real estate mortgages and the note received by the taxpayer upon these sales at their face value, and in determining the profit accordingly, but at the hearing no •competent evidence of the fair market value of these mortgages or the note was offered.

Taxpayer also claimed that the money to finance these transactions was furnished by his wife’s father upon the understanding that one-half of the profit should be the property of Mrs. Packman. The testimony, however, is insufficient satisfactorily to establish such an agreement.

Aiutndbll not participating.

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[509]*509OPINION.

Phillips:

Taxpayer alleges that the Commissioner committed error in fixing the value of the real estate mortgages and the note received by the taxpayer upon these sales at their face value, and in determining the profit accordingly, but at the hearing no •competent evidence of the fair market value of these mortgages or the note was offered.

Taxpayer also claimed that the money to finance these transactions was furnished by his wife’s father upon the understanding that one-half of the profit should be the property of Mrs. Packman. The testimony, however, is insufficient satisfactorily to establish such an agreement.

Aiutndbll not participating.

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2 B.T.A. 508, Counsel Stack Legal Research, https://law.counselstack.com/opinion/appeal-of-packman-bta-1925.

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