Guitar Trust Estate v. Commissioner
United States Board of Tax Appeals
1. Where respondent determined deficiencies against petitioner as an association, and it is later adjudicated that petitioner's tax liabilities should have been determined as a trust, the respondent's determination of petitioner's net income for each year as an association is prima facie correct as to the amounts of net income and the burden of proof is upon the party who alleges that petitioner's net income as a trust is either more or less than its net income as an…
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1. Where respondent determined deficiencies against petitioner as an association, and it is later adjudicated that petitioner's tax liabilities should have been determined as a trust, the respondent's determination of petitioner's net income for each year as an association is prima facie correct as to the amounts of net income and the burden of proof is upon the party who alleges that petitioner's net income as a trust is either more or less than its net income as an association. 2. The original deed of trust remained in effect without change during the years 1922 to 1931, inclusive, and…
1Opinion of the Court
GUITAR TRUST ESTATE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Guitar Trust Estate v. Commissioner
Docket Nos. 35102, 51432, 56931, 64535, 69665, 75823.
United States Board of Tax Appeals
34 B.T.A. 857; 1936 BTA LEXIS 634;
August 4, 1936, Promulgated
1. Where respondent determined deficiencies against petitioner as an association, and it is later adjudicated that petitioner's tax liabilities should have been determined as a trust, the respondent's determination of petitioner's net income for each year as an association is prima facie correct as to the amounts of net income and…
2Cases cited13 opinions
- Helvering v. ButterworthSupreme Court of the United States · 1933
- Old Mission Portland Cement Co. v. HelveringSupreme Court of the United States · 1934
- Crocker v. MalleySupreme Court of the United States · 1919
- Commissioner of Internal Revenue v. StearnsCourt of Appeals for the Second Circuit · 1933
- Willcuts v. OrdwayCourt of Appeals for the Eighth Circuit · 1927
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