Carey v. Commissioner

*577OPINION.

Black:

We will dispose of the issues in the order of their statement. The first issue is as to the amount of taxable gain received by petitioner Carey on the redemption in 1926 of preferred stock which he owned in Boxboard. Respondent made the allocation of costs in accordance with his regulations, approved in Glenn H. Curtiss, 21 B.T.A. 629; aff'd., 57 Fed. (2d) 847. Petitioner introduced no evidence to show that respondent’s allocation of cost between the two classes of stock was incorrect. There being no evidence to overturn respondent’s allocation of cost, it remains unchanged.…