Edwards v. Commissioner
United States Board of Tax Appeals
1. Book values of the assets of a corporation, held, in the absence of other evidence, sufficient to constitute a prima facie showing by petitioner that the corporation's stock was not worthless in prior years. 2. The Board will not take judicial notice of matters merely by reason of the fact that they are contained in its files.
1Opinion of the Court
*737OPINION.
Opper :
The sole issue is whether stock sold by petitioner in 1935 was actually worthless in a prior year. To sustain his burden of proof that it was not, petitioner produced balance sheets of the corporation whose stock was Involved upon which the assets are given a substantial value. The assets of a corporation may be considered in arriving at tile value of its stock, Lillian G. McEwan, 26 B. T. A. 726, and in the absence of any different showing, the book value of those assets is some evidence of their actual value sufficient to shift the burden *738of going forward to the respondent.…
2Cases cited2 opinions
- Ohio Bell Telephone Co. v. Public Utilities CommissionSupreme Court of the United States · 1937
- United States & Interstate Commerce Commission v. Abilene & Southern Railway Co.Supreme Court of the United States · 1924
3Cited by34 opinions
- Badger Materials, Inc. v. CommissionerUnited States Tax Court · 1963
- Funk v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1947
- Thorrez v. CommissionerUnited States Tax Court · 1958
- Barnhart-Morrow Consolidated v. CommissionerCourt of Appeals for the Ninth Circuit · 1945
- Newhouse v. CommissionerUnited States Tax Court · 1973
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