Appeal of Peters Manufacturing Co.

Board of Tax Appeals

Appeal of Peters Manufacturing Co.

1 B.T.A. 1198

CourtUnited States Board of Tax Appeals

DecidedMay 21, 1925

DocketDocket No. 2091

StatusPublished

Cited by1 cases

This text of 1 B.T.A. 1198 (Appeal of Peters Manufacturing Co.) 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 Peters Manufacturing Co., 1 B.T.A. 1198 (bta 1925).

Pincite

Opinion

[1200]*1200OPINION.

Trammell:

The taxpayer has failed to produce evidence to substantiate its contention with respect to the deductions claimed, and the Commissioner’s action in respect thereto is therefore approved.

The only question with respect to invested capital is the amount of the surplus, if any, of the New York branch of the business. The books were lost or destroyed and the taxpayer has established by competent evidence the contents thereof so far as material to this appeal.

We are satisfied from the evidence that the New York branch had a surplus for invested capital purposes for 1918 in the amount of $77,839.09 and for 1919 in the amount of $55,243.11, as claimed by the taxpayer. These amounts should be added to the invested capital found by the Commissioner for the respective years.

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