Legal Opinion

Fidelity & Deposit Co. v. Commissioner

United States Board of Tax Appeals

Decided July 20, 1926No. Docket No. 3503Published

1. The Board has jurisdiction of an appeal by the taxpayer from the determination of a deficiency, the sole object of which appeal is to secure a determination by the Board that the deficiency should be increased. 2. Evidence in the record reviewed and held to be insufficient to enable the Board to determine whether the treatment accorded by the Commissioner to certain payments made by the taxpayer was correct or incorrect.

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1. The Board has jurisdiction of an appeal by the taxpayer from the determination of a deficiency, the sole object of which appeal is to secure a determination by the Board that the deficiency should be increased. 2. Evidence in the record reviewed and held to be insufficient to enable the Board to determine whether the treatment accorded by the Commissioner to certain payments made by the taxpayer was correct or incorrect. In the circumstances, the determination made by the Commissioner must be approved.

1Opinion of the Court

APPEAL OF FIDELITY & DEPOSIT CO. OF MARYLAND.

Fidelity & Deposit Co. v. Commissioner

Docket No. 3503.

United States Board of Tax Appeals

4 B.T.A. 283; 1926 BTA LEXIS 2328;

July 20, 1926, Decided

1. The Board has jurisdiction of an appeal by the taxpayer from the determination of a deficiency, the sole object of which appeal is to secure a determination by the Board that the deficiency should be increased.

2. Evidence in the record reviewed and held to be insufficient to enable the Board to determine whether the treatment accorded by the Commissioner to certain payments made by the taxpayer was…

2Cases cited1 opinion

  1. Fidelity & Deposit Co. v. CommissionerUnited States Board of Tax Appeals · 1926

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