Behr v. Commissioner
United States Board of Tax Appeals
Where in his petition a petitioner admits receiving an amount in distribution of property of a taxpayer, but makes no admission as to the financial condition of the taxpayer immediately after the distribution or that the Commissioner had exhausted all of his remedies against the taxpayer for the collection of the tax being asserted against him as a transferee, such a petitioner may, under the circumstances present here, at the conclusion of the hearing amend his petition to…
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Where in his petition a petitioner admits receiving an amount in distribution of property of a taxpayer, but makes no admission as to the financial condition of the taxpayer immediately after the distribution or that the Commissioner had exhausted all of his remedies against the taxpayer for the collection of the tax being asserted against him as a transferee, such a petitioner may, under the circumstances present here, at the conclusion of the hearing amend his petition to conform to the proof by alleging as error the Commissioner's determination that he is a transferee. Such admissions do…
1Opinion of the Court
CHARLES B. BEHR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
GORE BROTHERS, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
ADOLPH RAMISH, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
ADOLPH RAMISH, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Behr v. Commissioner
Docket Nos. 39534, 39538, 39568, 39569.
United States Board of Tax Appeals
30 B.T.A. 1291; 1934 BTA LEXIS 1191;
July 27, 1934, Promulgated
Where in his petition a petitioner admits receiving an amount in distribution of property of a taxpayer, but makes no admission as…
2Cases cited1 opinion
- Behr v. CommissionerUnited States Board of Tax Appeals · 1934