Legal Opinion

Goodell-Pratt Co. v. Commissioner

United States Board of Tax Appeals

Decided May 4, 1927No. Docket No. 5884Published

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

GOODELL-PRATT CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Goodell-Pratt Co. v. Commissioner

Docket No. 5884.

United States Board of Tax Appeals

6 B.T.A. 1235; 1927 BTA LEXIS 3304;

May 4, 1927, Promulgated

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.

Lawrence A. Baker, Esq., and R. L. P. Wallace, Esq., for the petitioner.

John D. Foley, Esq., for the…

2Cases cited3 opinions

  1. Union Metal Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1926
  2. Goodell-Pratt Co. v. CommissionerUnited States Board of Tax Appeals · 1925
  3. Goodell-Pratt Co. v. CommissionerUnited States Board of Tax Appeals · 1927

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