Legal Opinion

Downing v. Commissioner

United States Board of Tax Appeals

Decided July 6, 1928No. Docket No. 13492Published

1. Respondent's determination of March 1, 1913, value of certain shares of stock sold sustained for lack of evidence proving error. 2. In 1920 the petitioners sold the stock and received in that year payments in excess of 33 per cent of the sales price. Held, the petitioners are not entitled to report the profit realized on the transaction on an installment basis.

1Opinion of the Court

ESTATE OF JEREMIAH ROBERTS DOWNING, EVERETT MORSE, FRANK G. NEWHALL AND JERE R. DOWNING, TRUSTEES, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Downing v. Commissioner

Docket No. 13492.

United States Board of Tax Appeals

12 B.T.A. 1180; 1928 BTA LEXIS 3385;

July 6, 1928, Promulgated

1. Respondent's determination of March 1, 1913, value of certain shares of stock sold sustained for lack of evidence proving error.

2. In 1920 the petitioners sold the stock and received in that year payments in excess of 33 per cent of the sales price. Held, the petitioners are not entitled to report…

2Cases cited1 opinion

  1. Downing v. CommissionerUnited States Board of Tax Appeals · 1928

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