Goodell-Pratt Co. v. Commissioner
United States Board of Tax Appeals
The findings of fact made by the Board in an earlier proceeding as to liability for earlier years are prima facie evidence of the facts therein stated when offered in a subsequent proceeding involving the same question of fact as related to liability for a later year.
1Opinion of the Court
*1237OPINION.
Steenhagen :
The petitioner introduced in evidence a copy of the findings of fact made by the Board in its earlier decision in Goodell-Pratt Co., 3 B. T. A. 30, and also asked at the hearing that the Board take judicial notice of its earlier decision. Judicial notice was taken of the fact that such decision had been made, and the copy thereof was received as evidence of the facts therein found, objections thereto being overruled. By oral testimony such facts were then proven to have been no less applicable to 1920 than to the earlier years. No countervailing evidence was introduced.
The…
2Cited by4 opinions
- Funk v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1947
- Goodell-Pratt Co. v. CommissionerUnited States Board of Tax Appeals · 1927
- McMillan v. Comm'rUnited States Tax Court · 2015
- St. Louis Malleable Casting Co. v. CommissionerUnited States Board of Tax Appeals · 1931