Batcheller v. Commissioner
United States Board of Tax Appeals
1. Respondent's determination of the fair market value of purchase money notes approved for lack of evidence to overcome its prima facie correctness. 2. The Board will not accept the opinion of a witness as to the fair market value of purchase money notes when it does not appear that the witness is qualified as an expert to express an authoritative opinion of the value of such notes.
1Opinion of the Court
*1052OPINION.
McMahon:
The respondent concedes error in his denial of a deduction of $592 representing ordinary and necessary business expenses for the year 1924. This deduction will, therefore, be allowed.
The only other error alleged in the petition is that the respondent refused to compute the profit upon the sale to Lett upon the installment sale basis provided in section 212 (d) of the Revenue Act of 1926.
The respondent treated the transaction as closed in the year 1924 and determined that the entire profit upon the sale was realized in 1924. He held that the fair market value of the notes at…
2Cited by15 opinions
- Robert B. Riss and Georgina Riss v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1966
- Irwin v. CommissionerUnited States Tax Court · 1966
- Maddox v. CommissionerUnited States Tax Court · 1978
- Ivan Irwin, Jr. And Ann Vanston Irwin v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Bostedt v. CommissionerUnited States Tax Court · 1978
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