Carey v. Commissioner
United States Board of Tax Appeals
1. ALLOCATION OF COST - FAILURE OF PROOF TO OVERCOME RESPONDENT'S DETERMINATION. - During 1926 the Boxboard Products Co., of which petitioner Carey was a preferred and common stockholder, redeemed all of its preferred stock. Respondent, in determining the gain on the redemption, made an allocation of costs in accordance with his regulations, which is prima facie correct. Petitioner introduced no evidence to show that respondent's allocation of cost was incorrect.
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1. ALLOCATION OF COST - FAILURE OF PROOF TO OVERCOME RESPONDENT'S DETERMINATION. - During 1926 the Boxboard Products Co., of which petitioner Carey was a preferred and common stockholder, redeemed all of its preferred stock. Respondent, in determining the gain on the redemption, made an allocation of costs in accordance with his regulations, which is prima facie correct. Petitioner introduced no evidence to show that respondent's allocation of cost was incorrect. Respondent sustained. 2. DIVIDENDS - MOST RECENTLY ACCUMULATED EARNINGS OR PROFITS DETERMINED WHERE ENTIRE ISSUE OF DECLARING…
1Opinion of the Court
W. GIBSON CAREY, JR., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
ISAAC HARTER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Carey v. Commissioner
Docket Nos. 46599, 58009 61445.
United States Board of Tax Appeals
30 B.T.A. 572; 1934 BTA LEXIS 1311;
April 27, 1934, Promulgated
1. ALLOCATION OF COST - FAILURE OF PROOF TO OVERCOME RESPONDENT'S DETERMINATION. - During 1926 the Boxboard Products Co., of which petitioner Carey was a preferred and common stockholder, redeemed all of its preferred stock. Respondent, in determining the gain on the redemption, made an…
2Cases cited2 opinions
- Stewart v. CommissionerUnited States Board of Tax Appeals · 1934
- Carey v. CommissionerUnited States Board of Tax Appeals · 1934