Appeal of Valley Steamship Co.

Board of Tax Appeals

Appeal of Valley Steamship Co.

1 B.T.A. 1107

CourtUnited States Board of Tax Appeals

DecidedMay 5, 1925

DocketDocket No. 1043

StatusPublished

Cited by2 cases

This text of 1 B.T.A. 1107 (Appeal of Valley Steamship 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 Valley Steamship Co., 1 B.T.A. 1107 (bta 1925).

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Opinion

[1108]*1108OPINION.

Green:

This appeal and the Appeal of The Kinsman Transit Co., 1 B. T. A. 552, are almost identical. The counsel for the taxpayer was the same in each instance. In that appeal it was clearly pointed out that value was a question of fact and that it could not Jbe proven by formulae alone. A formula without some facts to which to apply it is useless. There is not in the record in this appeal a single fact upon which we could base a determination of value. No witness has testified to the actual value on March 1, 1913. The evidence contains no statement as to cost or date of construction. We do not even know the valuation fixed by the Commissioner, and yet we are asked to hold that such valuation is erroneous because the Commissioner used a flat, instead of a progressive, depreciation rate.

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[1108]*1108OPINION.

Green:

This appeal and the Appeal of The Kinsman Transit Co., 1 B. T. A. 552, are almost identical. The counsel for the taxpayer was the same in each instance. In that appeal it was clearly pointed out that value was a question of fact and that it could not Jbe proven by formulae alone. A formula without some facts to which to apply it is useless. There is not in the record in this appeal a single fact upon which we could base a determination of value. No witness has testified to the actual value on March 1, 1913. The evidence contains no statement as to cost or date of construction. We do not even know the valuation fixed by the Commissioner, and yet we are asked to hold that such valuation is erroneous because the Commissioner used a flat, instead of a progressive, depreciation rate.

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1 B.T.A. 1107, Counsel Stack Legal Research, https://law.counselstack.com/opinion/appeal-of-valley-steamship-co-bta-1925.

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