Daigger v. Commissioner
This text of 13 B.T.A. 35 (Daigger v. Commissioner) 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.
Opinion
[37]*37OPINION.
Although the question here relates to inventories, it resolves itself into a question of fact as to the market value on December 31, 1920, of certain goods purchased in Germany. We have found that this market value was $3,769.02. We turn now to the effect that such a finding will have on the deficiencies determined by the respondent.
The respondent determined the deficiency for 1920 on the basis of a total closing inventory for that year of $135,712.95 and a net income of $39,623.68. We find that the correct inventory is $116,707.75, which results in a correct net income for 1920 of $20,618.48.
The respondent determined the deficiency for 1921 on the basis of a total opening inventory for that year of $119,422.62 and a net income of $7,974.87. We find that the correct inventory is $116,707.75, which results in a correct net income for 1921 of $10,689.74.
The deficiencies should be redetermined in accordance with the above opinion.
Judgment will be entered wider Buie SO.
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13 B.T.A. 35, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daigger-v-commissioner-bta-1928.