Union Title Co. v. Commissioner

Board of Tax Appeals

Union Title Co. v. Commissioner

5 B.T.A. 61, 1926 BTA LEXIS 1991

CourtUnited States Board of Tax Appeals

DecidedOctober 13, 1926

DocketDocket No. 5319.

StatusPublished

Cited by1 cases

This text of 5 B.T.A. 61 (Union Title 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

Union Title Co. v. Commissioner, 5 B.T.A. 61, 1926 BTA LEXIS 1991 (bta 1926).

Pincite

Opinion

Lansdon:

This appeal is from a deficiency of $4,964.95, income and profits taxes for the calendar years 1919, 1920 and 1921. The deficiency arises from the refusal of the Commissioner to allow as invested capital, at the time of the organization of the company, any amount in excess of the full amount paid in 1903 for the capital stock and assets of Reed & Burt, from whom all the assets of the taxpayer were purchased.

The petitioner called three witnesses to testify at the hearing. Rone of such witnesses was an officer of the Union Title Co. or qualified in any way to testify as to the issues in controversy. There is no evidence in the record sufficient to warrant the Board in disturbing the Commissioner’s determination.

Judgment will be entered for the Qornrrm-sioner.

Free access — add to your briefcase to read the full text and ask questions with AI

Lansdon:

This appeal is from a deficiency of $4,964.95, income and profits taxes for the calendar years 1919, 1920 and 1921. The deficiency arises from the refusal of the Commissioner to allow as invested capital, at the time of the organization of the company, any amount in excess of the full amount paid in 1903 for the capital stock and assets of Reed & Burt, from whom all the assets of the taxpayer were purchased.

The petitioner called three witnesses to testify at the hearing. Rone of such witnesses was an officer of the Union Title Co. or qualified in any way to testify as to the issues in controversy. There is no evidence in the record sufficient to warrant the Board in disturbing the Commissioner’s determination.

Judgment will be entered for the Qornrrm-sioner.

Cite This Page — Counsel Stack

Bluebook (online)

5 B.T.A. 61, 1926 BTA LEXIS 1991, Counsel Stack Legal Research, https://law.counselstack.com/opinion/union-title-co-v-commissioner-bta-1926.

Opinion

Related

Cite This Page — Counsel Stack