Rauh v. Commissioner
United States Board of Tax Appeals
1. Henry Cappellini et al.,14 B.T.A. 1269, followed. 2. The respondent has failed to sustain the burden of proof that the petitioner is liable as a transferee within the meaning of section 280 of the Revenue Act of 1926. 3. The statute of limitations does not bar the collection of the liability here in controversy.
1Opinion of the Court
CHARLES S. RAUH, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Rauh v. Commissioner
Docket No. 19226.
United States Board of Tax Appeals
22 B.T.A. 662; 1931 BTA LEXIS 2093;
March 10, 1931, Promulgated
1. Henry Cappellini et al.,14 B.T.A. 1269, followed.
2. The respondent has failed to sustain the burden of proof that the petitioner is liable as a transferee within the meaning of section 280 of the Revenue Act of 1926.
3. The statute of limitations does not bar the collection of the liability here in controversy.
Frank C. Olive, Esq., for the petitioner.
J. A. Lyons, Esq., for the…
2Cases cited7 opinions
- Cappellini v. CommissionerUnited States Board of Tax Appeals · 1929
- Vogelstein v. CommissionerUnited States Board of Tax Appeals · 1929
- Steinle v. CommissionerUnited States Board of Tax Appeals · 1930
- Gleichman v. CommissionerUnited States Board of Tax Appeals · 1929
- Metropolitan Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1930
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