Citizens State Bank v. Commissioner
United States Board of Tax Appeals
EVIDENCE - BURDEN OF PROOF. - Upon an issue of whether the recovered portions of deductions for had debts taken in prior years are income in the year of recovery, the petitioner carries its burden of proof where the stipulated facts show that the deductions did not result in tax benefits, and the petitioner is not required to negative possibilities concerning which no facts were stipulated and which were suggested for the first time in the respondent's brief.
1Opinion of the Court
CITIZENS STATE BANK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Citizens State Bank v. Commissioner
Docket No. 106122.
United States Board of Tax Appeals
46 B.T.A. 964; 1942 BTA LEXIS 796;
April 14, 1942, Promuigated
EVIDENCE - BURDEN OF PROOF. - Upon an issue of whether the recovered portions of deductions for had debts taken in prior years are income in the year of recovery, the petitioner carries its burden of proof where the stipulated facts show that the deductions did not result in tax benefits, and the petitioner is not required to negative possibilities concerning which no…
2Cases cited1 opinion
- Citizens State Bank v. CommissionerUnited States Board of Tax Appeals · 1942