Legal Opinion

First Nat'l Bank v. Commissioner

United States Board of Tax Appeals

Decided November 15, 1933No. Docket Nos. 54372, 63374Published

1. Opinions respecting values of properties, although expressed by those in a position to know, in the absence of supporting data upon which they are based, will not be accepted in substitution for proof of positive facts. Tracy v. Commissioner, 53 Fed.(2d) 575. 2. Cost to be used for determining gain or loss on corporate stock acquired from a converted investment made prior to March 1, 1913, determined.

1Opinion of the Court

FIRST NATIONAL BANK OF BIRMINGHAM, TRUSTEE, E. T. SCHULER TRUST FUND, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

First Nat'l Bank v. Commissioner

Docket Nos. 54372, 63374.

United States Board of Tax Appeals

29 B.T.A. 352; 1933 BTA LEXIS 953;

November 15, 1933, Promulgated

1. Opinions respecting values of properties, although expressed by those in a position to know, in the absence of supporting data upon which they are based, will not be accepted in substitution for proof of positive facts. Tracy v. Commissioner, 53 Fed.(2d) 575.

2. Cost to be used for determining gain or loss on…

2Cases cited1 opinion

  1. First Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1933

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