First National Bank v. Commissioner of Internal Revenue

The petitioner challenges findings made by the Board of Tax Appeals upon the value of real estate and leasehold interests of the petitioner on the ground that the Board disregarded the uncontroverted evidence of opinion witnesses, and that its findings are therefore not supported by substantial evidence.

It is the view of the court that there was sufficient data before the Board to enable it, as a tribunal developed by experience to expertness in valuations, to sustain its findings; that such data includes the length of the leases, the rentals therein provided, the percentages of occupancy and…