Clearfield Lumber Co. v. Commissioner
United States Board of Tax Appeals
1. The taxpayer, prior to March 1, 1913, acquired timberlands at a cost of approximately $3.50 per thousand feet of timber. From the evidence submitted, held, that the fair market value of said standing timber on March 1, 1913, was not more than $5.35 per thousand. 2. The taxpayer issued $360,000 preferred stock for timber and timberlands in 1907, and $480,000 common stock for cash or its equivalent at or about the same time.
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1. The taxpayer, prior to March 1, 1913, acquired timberlands at a cost of approximately $3.50 per thousand feet of timber. From the evidence submitted, held, that the fair market value of said standing timber on March 1, 1913, was not more than $5.35 per thousand. 2. The taxpayer issued $360,000 preferred stock for timber and timberlands in 1907, and $480,000 common stock for cash or its equivalent at or about the same time. Thereafter, from 1909 to 1918, inclusive, the taxpayer retired all the preferred stock and $280,000 par value of common stock for cash. Held, that such retirement of…
1Opinion of the Court
*1287OPINION.
James:
Summarized, the taxpayer complains of the determinations of the Commissioner giving rise to the deficiency in the instant appeal, as follows:(1) That he has valued its stumpage at March 1, 1913, for purposes of depletion and computation of gain or loss on sales, at $5.35, whereas the true and correct value as of that date was $8.60.(2) That the Commissioner made substantially the same errors in the year 1917, thereby computing a greater tax liability for that year than the taxpayer owed, and in consequence, in accordance with his usual method, decreased by too great an amount…
2Cases cited4 opinions
- LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
- Lynch v. HornbySupreme Court of the United States · 1918
- Lynch v. TurrishSupreme Court of the United States · 1918
- Goodrich v. EdwardsSupreme Court of the United States · 1921
3Cited by9 opinions
- W. M. Ritter Lumber Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Sneed v. CommissionerUnited States Board of Tax Appeals · 1934
- Badger Lumber Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- American Cigar Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Clearfield Lumber Co. v. CommissionerUnited States Board of Tax Appeals · 1926
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