Lyon v. Commissioner
United States Board of Tax Appeals
A taypayer must introduce sufficient evidence to make a prima facie showing that the Commissioner committed errors in determining a deficiency before the Board can disallow such deficiency.
1Opinion of the Court
OFINION.
Graupner :
In deciding this appeal we do not determine that the taxpayer was not entitled to make his income-tax return upon an installment basis. Had sufficient evidence been submitted for our consideration, his appeal might have merited a favorable decision.
Bule 20 of this Board provides that the burden of proof is on the taxpayer. That means that he must introduce sufficient evidence to make a prima facie showing that the Commissioner committed the errors alleged in the petition and to overcome the proofs submitted on behalf of the Commissioner. Such a showing must cover all the…
2Cited by26 opinions
- G.D. Searle & Co. v. CommissionerUnited States Tax Court · 1987
- Estate of Trenchard v. CommissionerUnited States Tax Court · 1995
- Grandview Mines v. CommissionerUnited States Tax Court · 1959
- Lawler v. CommissionerUnited States Tax Court · 1995
- Schuler v. CommissionerUnited States Board of Tax Appeals · 1933
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