Wood v. Commissioner

Board of Tax Appeals

Wood v. Commissioner

1 B.T.A. 957, 1925 BTA LEXIS 2731

CourtUnited States Board of Tax Appeals

DecidedApril 7, 1925

DocketDocket No. 696.

StatusPublished

This text of 1 B.T.A. 957 (Wood 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

Wood v. Commissioner, 1 B.T.A. 957, 1925 BTA LEXIS 2731 (bta 1925).

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Opinion

[958]*958OPINION.

James:

In the foregoing appeal no material fact alleged by the taxpayer in the petition was admitted by the Commissioner. The taxpayer was granted three separate opportunities- to appear and present evidence in support of the petition. On each of these three occasions, the taxpayer failed to avail himself of the opportunity so extended. In justice to taxpayers prepared to prosecute their appeals, the Board may not permit its calendar to be encumbered by taxpayers who by themselves or through their counsel adopt dilatory tactics to delay the hearing of their appeals.

There being no evidence on which the Board can act in this appeal, the determination of the Board must be that the deficiency heretofore determined by the Commissioner is approved.

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[958]*958OPINION.

James:

In the foregoing appeal no material fact alleged by the taxpayer in the petition was admitted by the Commissioner. The taxpayer was granted three separate opportunities- to appear and present evidence in support of the petition. On each of these three occasions, the taxpayer failed to avail himself of the opportunity so extended. In justice to taxpayers prepared to prosecute their appeals, the Board may not permit its calendar to be encumbered by taxpayers who by themselves or through their counsel adopt dilatory tactics to delay the hearing of their appeals.

There being no evidence on which the Board can act in this appeal, the determination of the Board must be that the deficiency heretofore determined by the Commissioner is approved.

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1 B.T.A. 957, 1925 BTA LEXIS 2731, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wood-v-commissioner-bta-1925.

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