William T. Reynolds Co. v. Commissioner

Board of Tax Appeals

William T. Reynolds Co. v. Commissioner

6 B.T.A. 16, 1927 BTA LEXIS 3623

CourtUnited States Board of Tax Appeals

DecidedFebruary 2, 1927

DocketDocket No. 3547.

StatusPublished

This text of 6 B.T.A. 16 (William T. Reynolds 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

William T. Reynolds Co. v. Commissioner, 6 B.T.A. 16, 1927 BTA LEXIS 3623 (bta 1927).

Pincite

Opinion

[18]*18OBINION.

GREEN:

Inasmuch as the Commissioner has not determined a deficiency for the period ending December 31, 1917, it is not necessary for us to determine whether the note of Paul I. Reynolds was properly excluded in the computation of invested capital for that year.

It appears that the notes and accounts receivable taken over by the corporation were not, in the opinion of the incorporators, worth their face value and that the reserve was set up to make the books of account reflect accurately the actual value of the notes and accounts receivable. This being true, the Commissioner’s action in excluding from invested capital the amount of the reserve was correct.

The petitioner offered no evidence as to the value of the depre-ciable assets or as to their remaining life, and while it may be that the Commissioner’s computation of depreciation is erroneous, the [19]*19petitioner has not provided us with the data upon which we may correctly compute the depreciation allowance, and we must, therefore, affirm the Commissioner upon this point.

The deficiencies heretofore determined by the Commissioner are redetermined to be the correct deficiencies and judgment will enter accordingly.

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