Guggenheimer v. Commissioner

Board of Tax Appeals

Guggenheimer v. Commissioner

15 B.T.A. 1406, 1929 BTA LEXIS 2669

CourtUnited States Board of Tax Appeals

DecidedApril 12, 1929

DocketDocket No. 27068.

StatusPublished

Cited by1 cases

This text of 15 B.T.A. 1406 (Guggenheimer 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.

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Guggenheimer v. Commissioner, 15 B.T.A. 1406, 1929 BTA LEXIS 2669 (bta 1929).

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Opinion

[1407]*1407OPINION.

Moeeis :

Beyond a mere recital of some of the deductions claimed, how they were arrived at, and the action of the respondent with respect thereto, we have no other facts .of record from which we may prepare findings of fact or .attempt to reach a decision with respect to the issues raised. While it is true that the petitioner offered his books of memoranda in evidence, from which he appears to have compiled his income for the years in question, we are unable to decipher the writing therein in some instances, and even if we could, there are not sufficient details therein to aid in the determination of the questions in issue. We are, therefore, compelled to conclude that the evidence is wholly insufficient to overcome the prima fade [1408]*1408correctness .of the respondent’s findings in any of the particulars urged by the petitioner.

Judgment will be entered for the respondent.

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[1407]*1407OPINION.

Moeeis :

Beyond a mere recital of some of the deductions claimed, how they were arrived at, and the action of the respondent with respect thereto, we have no other facts .of record from which we may prepare findings of fact or .attempt to reach a decision with respect to the issues raised. While it is true that the petitioner offered his books of memoranda in evidence, from which he appears to have compiled his income for the years in question, we are unable to decipher the writing therein in some instances, and even if we could, there are not sufficient details therein to aid in the determination of the questions in issue. We are, therefore, compelled to conclude that the evidence is wholly insufficient to overcome the prima fade [1408]*1408correctness .of the respondent’s findings in any of the particulars urged by the petitioner.

Judgment will be entered for the respondent.

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15 B.T.A. 1406, 1929 BTA LEXIS 2669, Counsel Stack Legal Research, https://law.counselstack.com/opinion/guggenheimer-v-commissioner-bta-1929.

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