Federal Schools, Inc. v. Commissioner

Board of Tax Appeals

Federal Schools, Inc. v. Commissioner

6 B.T.A. 179

CourtUnited States Board of Tax Appeals

DecidedFebruary 18, 1927

DocketDocket Nos. 9625, 13095

StatusPublished

This text of 6 B.T.A. 179 (Federal Schools, Inc. 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.

Bluebook

Federal Schools, Inc. v. Commissioner, 6 B.T.A. 179 (bta 1927).

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Opinion

[181]*181OPINION.

Trammell:

As the result of the stipulation entered into, the only question for 1919 is whether the petitioner is entitled to have its profits taxes assessed under the provisions of section 328 of the Revenue Act of 1918. All other alleged errors were waived. The net income and invested capital for both 1919 and 1921 were stipulated.

From the evidence introduced we find no abnormalities of income or capital which would warrant the assessment of the taxes under the provisions of section 328. The taxes should, therefore, be assessed in accordance with the foregoing findings of fact.

Judgment will be entered on 15 days’ notice, under Rule 50.

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[181]*181OPINION.

Trammell:

As the result of the stipulation entered into, the only question for 1919 is whether the petitioner is entitled to have its profits taxes assessed under the provisions of section 328 of the Revenue Act of 1918. All other alleged errors were waived. The net income and invested capital for both 1919 and 1921 were stipulated.

From the evidence introduced we find no abnormalities of income or capital which would warrant the assessment of the taxes under the provisions of section 328. The taxes should, therefore, be assessed in accordance with the foregoing findings of fact.

Judgment will be entered on 15 days’ notice, under Rule 50.

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Bluebook (online)

6 B.T.A. 179, Counsel Stack Legal Research, https://law.counselstack.com/opinion/federal-schools-inc-v-commissioner-bta-1927.