Legal Opinion

Couzens v. Commissioner

United States Board of Tax Appeals

Decided May 5, 1928No. Docket No. 10438Published

1. The function of the Board is not primarily to declare a rule but to determine the issues presented in each case in the light of the evidence therein, to the end that the present tax liability of each petitioner may be settled. 2. Where, during the negotiations for the sale of property by a taxpayer, a valuation of the property was sought from the Commissioner of Internal Revenue in order that the taxpayer could ascertain the extent of his tax liability in the event of…

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1. The function of the Board is not primarily to declare a rule but to determine the issues presented in each case in the light of the evidence therein, to the end that the present tax liability of each petitioner may be settled. 2. Where, during the negotiations for the sale of property by a taxpayer, a valuation of the property was sought from the Commissioner of Internal Revenue in order that the taxpayer could ascertain the extent of his tax liability in the event of sale, and the Commissioner stated a valuation, whereupon the sale was consummated and the tax computed and paid on the…

1Opinion of the Court

JAMES COUZENS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Couzens v. Commissioner

Docket No. 10438.

United States Board of Tax Appeals

11 B.T.A. 1040; 1928 BTA LEXIS 3663;

May 5, 1928, Promulgated

1. The function of the Board is not primarily to declare a rule but to determine the issues presented in each case in the light of the evidence therein, to the end that the present tax liability of each petitioner may be settled.

2. Where, during the negotiations for the sale of property by a taxpayer, a valuation of the property was sought from the Commissioner of Internal Revenue in…

2Cases cited20 opinions

  1. The Minnesota Rate CasesSupreme Court of the United States · 1913
  2. Wickwire v. ReineckeSupreme Court of the United States · 1927
  3. Southern Pacific Co. v. LoweSupreme Court of the United States · 1918
  4. Lynch v. HornbySupreme Court of the United States · 1918
  5. United States v. FlannerySupreme Court of the United States · 1925

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