Dehnke v. Commissioner

Board of Tax Appeals

Dehnke v. Commissioner

2 B.T.A. 1222, 1925 BTA LEXIS 2126

United States Board of Tax Appeals·Decided November 6, 1925·No. Docket No. 420.·Published

Opinion

OPINION.

Marquette:

We are unable to determine from the evidence presented the fair market value of the property in question as of March 1, 1913, or the cost of improvements and additions since that time. The testimony consisted of estimates by the taxpayer, not based [1223] on his recollection of cost, and contains nothing upon which we would feel justified in overturning the Commissioner’s findings. No books or records of any kind were introduced in evidence, and the evidence of record leaves the March 1, 1913, value and the amount of additions and improvements a matter of speculation.

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OPINION.

Marquette:

We are unable to determine from the evidence presented the fair market value of the property in question as of March 1, 1913, or the cost of improvements and additions since that time. The testimony consisted of estimates by the taxpayer, not based [1223] on his recollection of cost, and contains nothing upon which we would feel justified in overturning the Commissioner’s findings. No books or records of any kind were introduced in evidence, and the evidence of record leaves the March 1, 1913, value and the amount of additions and improvements a matter of speculation.

Dehnke v. Commissioner, 2 B.T.A. 1222, 1925 BTA LEXIS 2126 (bta 1925).

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Opinion

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