Peters Mfg. Co. v. Commissioner

Board of Tax Appeals

Peters Mfg. Co. v. Commissioner

1 B.T.A. 1198, 1925 BTA LEXIS 2637

CourtUnited States Board of Tax Appeals

DecidedMay 21, 1925

DocketDocket No. 2091.

StatusPublished

This text of 1 B.T.A. 1198 (Peters Mfg. Co. 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

Peters Mfg. Co. v. Commissioner, 1 B.T.A. 1198, 1925 BTA LEXIS 2637 (bta 1925).

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Opinion

[1200]*1200OPINION.

Trammell:

The taxpayer has failed to produce evidence to substantiate its contention with respect to the deductions claimed, and the Commissioner’s action in respect thereto is therefore approved.

The only question with respect to invested capital is the amount of the surplus, if any, of the New York branch of the business. The books were lost or destroyed and the taxpayer has established by competent evidence the contents thereof so far as material to this appeal.

We are satisfied from the evidence that the New York branch had a surplus for invested capital purposes for 1918 in the amount of $77,839.09 and for 1919 in the amount of $55,243.11, as claimed by the taxpayer. These amounts should be added to the invested capital found by the Commissioner for the respective years.

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