Robison v. Commissioner
United States Board of Tax Appeals
1. TRANSFEREE. - Held, petitioner Lester L. Robison not liable as transferee. Petitioner Elmer D. Bryson liable as transferee. 2. INCREASE OF DEFICIENCY. - Section 308(e) of the Act of 1926 gives the Board jurisdiction to increase the deficiency over that determined by the Commissioner, if asserted by the Commissioner before or at the hearing, and the action of the Board in permitting respondent to amend his answer to that effect is not error. 3. LIMITATION. - The burden of…
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1. TRANSFEREE. - Held, petitioner Lester L. Robison not liable as transferee. Petitioner Elmer D. Bryson liable as transferee. 2. INCREASE OF DEFICIENCY. - Section 308(e) of the Act of 1926 gives the Board jurisdiction to increase the deficiency over that determined by the Commissioner, if asserted by the Commissioner before or at the hearing, and the action of the Board in permitting respondent to amend his answer to that effect is not error. 3. LIMITATION. - The burden of proof to establish the plea of limitation is on petitioners and where it is not shown when the return was filed the plea…
1Opinion of the Court
*398OPINION.
Black :
Each of the petitioners based his appeal on the following assignments of error:
That the Commissioner of Internal Revenue in arriving at the amount of the invested capital of the Bryson-Robison Corporation erroneously reduced the said invested capital by the sum of $45,000.00.
That the Commissioner in arriving at the net income of the Bryson-Robison Corporation in error disallowed the salaries of the corporation officers for the years 1917 and 1919. That said lawful and proper deduction for salaries during 1917 was the sum of $10,000, (the same as allowed in 1918), and for 1919…
2Cases cited1 opinion
- LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
3Cited by8 opinions
- Cherry v. United StatesDistrict Court, C.D. California · 1967
- Eleanor H. Vendig, as Alleged Transferee of the Assets of Mavco Sales, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956
- Waggaman v. CommissionerUnited States Board of Tax Appeals · 1933
- Brodsky v. CommissionerUnited States Tax Court · 1962
- Robison v. CommissionerUnited States Board of Tax Appeals · 1931
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