Mead Realty Co. v. Commissioner
United States Board of Tax Appeals
1. PROCEDURE IN THE OFFICE OF THE COMMISSIONER. - The petitioner has been accorded full opportunity in a hearing before this Board on the merits; consequently, a complaint with respect to procedure in the office of the Commissioner is of no significance. 2. INCOME FROM CERTAIN SALES FOR A CASH CONSIDERATION, - is determinable to this corporation petitioner for 1922 and 1923 under section 202(a) of the Revenue Act of 1921, and "cost" is held to be the value of the property in…
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1. PROCEDURE IN THE OFFICE OF THE COMMISSIONER. - The petitioner has been accorded full opportunity in a hearing before this Board on the merits; consequently, a complaint with respect to procedure in the office of the Commissioner is of no significance. 2. INCOME FROM CERTAIN SALES FOR A CASH CONSIDERATION, - is determinable to this corporation petitioner for 1922 and 1923 under section 202(a) of the Revenue Act of 1921, and "cost" is held to be the value of the property in 1916 when paid in to the petitioner for its capital stock plus any allowable amounts of additional cost. 3.…
1Opinion of the Court
*1065OPINION.
TRtjssell:
The petitioner offers eight contentions, but it appears at once upon examination of the record that they relate to but three major issues, which may be summarized as follows: (1) Raised in contention No. 1: petitioner was not accorded a hearing by the Commissioner prior to the assessment of the deficiencies; (2) raised in various details in contentions No. 2 to No. 7, inclusive: the basis for the computation of the profits derived, by the petitioner from sales of lots in a certain subdivision should be that of the prior owners who turned the land over to the petitioner for…
2Cited by15 opinions
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- Dr. G. H. Tichenor Antiseptic Co. v. United StatesDistrict Court, E.D. Louisiana · 1948
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