Hoey v. Commissioner

APPEAL OF JAMES F. HOEY.

Hoey v. Commissioner

Docket No. 6155.

United States Board of Tax Appeals

4 B.T.A. 1043; 1926 BTA LEXIS 2102;

September 25, 1926, Decided

William E. Howe, C.P.A., for the petitioner.

George G. Witter, Esq., for the Commissioner.

STERNHAGEN

STERNHAGEN: The petitioner sold his laundry business in 1922 for $200,000 and in his tax return he included no part thereof, on the theory that the price was not in excess of its value on March 1, 1913. The deficiency letter is not before us, but we are told that the Commissioner regarded part of the sale price as gain and so determined the…