Miller v. Commissioner

Board of Tax Appeals

Miller v. Commissioner

15 B.T.A. 13

CourtUnited States Board of Tax Appeals

DecidedJanuary 23, 1929

DocketDocket No. 20267

StatusPublished

This text of 15 B.T.A. 13 (Miller 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

Miller v. Commissioner, 15 B.T.A. 13 (bta 1929).

Pincite

Opinion

[15]*15OPINION.

Smith :

In computing petitioner’s tax liability for the year 1920 the Commissioner increased net income by adding to the closing lumber inventory an arbitrary amount based upon the ratio of purchases to amounts charged off to depreciation over several preceding and subsequent years.

Upon consideration of the entire record we are of the opinion that petitioner’s inventory for the taxable year 1920 clearly reflected its income and that the Commissioner’s adjustment thereof was error.

iJudgment will be entered wider Bule 50.

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[15]*15OPINION.

Smith :

In computing petitioner’s tax liability for the year 1920 the Commissioner increased net income by adding to the closing lumber inventory an arbitrary amount based upon the ratio of purchases to amounts charged off to depreciation over several preceding and subsequent years.

Upon consideration of the entire record we are of the opinion that petitioner’s inventory for the taxable year 1920 clearly reflected its income and that the Commissioner’s adjustment thereof was error.

iJudgment will be entered wider Bule 50.

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Bluebook (online)

15 B.T.A. 13, Counsel Stack Legal Research, https://law.counselstack.com/opinion/miller-v-commissioner-bta-1929.