Roberts v. Commissioner
United States Board of Tax Appeals
Held that the cash paid for stock was its entire purchase price and that no part of the price was paid in services.
1Opinion of the Court
*354OPINION.
Trammell :
The parties stated at the hearing that the proceedings in the two dockets here involved were to be consolidated. However, an examination of the petition in Docket No. 22483 shows that the appeal was not taken from notice of a determination of a deficiency, but from a letter from the respondent advising the petitioner of the privilege of having a hearing in the Income Tax Unit with respect to his tax liability for 1923 prior to a final determination of such liability. Since the petition was not based upon a notice of a determination of a deficiency, we have no jurisdiction of…
2Cases cited9 opinions
- McCord v. MartinCalifornia Court of Appeal · 1920
- Sheehy v. MandevilleSupreme Court of the United States · 1812
- Alexander v. HarrisSupreme Court of the United States · 1808
- Wilson v. DuncanCourt of Appeals of Texas · 1924
- Du Pont Engineering Co. v. BlairSupreme Court of Virginia · 1921
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3Cited by2 opinions
- Second Carey Trust v. HelveringCourt of Appeals for the D.C. Circuit · 1942
- Roberts v. CommissionerUnited States Board of Tax Appeals · 1930