Koelle v. Commissioner

Board of Tax Appeals

Koelle v. Commissioner

7 B.T.A. 917, 1927 BTA LEXIS 3061

CourtUnited States Board of Tax Appeals

DecidedAugust 1, 1927

DocketDocket No. 6093.

StatusPublished

Cited by1 cases

This text of 7 B.T.A. 917 (Koelle 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

Koelle v. Commissioner, 7 B.T.A. 917, 1927 BTA LEXIS 3061 (bta 1927).

Pincite

Opinion

[918]*918OPINION.

Love:

As set out in the findings of fact, the check for $25,000 given in settlement of the petitioner’s claim against his brother, did not reach the petitioner’s attorney until January 7,1924. Obviously, therefore, the respondent erred in including any part of that amount as income for the year 1923.

A copy of the deficiency notice was not attached to the petition herein, nor was it introduced in evidence at the hearing. Consequently, we are unable to determine the deficiency, if any, for the year 1923.

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

Considered by Smith and Littleton.

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