Pioneer Cooperage Co. v. Commissioner
United States Board of Tax Appeals
The basis for the computation of loss on property acquired prior to March 1, 1913, and lost by casualty in the years 1918 and 1919, is cost where its value on March 1, 1913, was in excess of its cost.
1Opinion of the Court
*121OPINION.
Milliken:
Since respondent has not determined a deficiency for the year 1917 but has determined an overassessment, and such over-assessment, so far as the record discloses, not resulting from the rejection of a claim in abatement, the Board is accordingly without jurisdiction as to that year and for that reason this appeal, in so far as that year is involved, is dismissed. Cornelius Cotton Mills, 4 B. T. A. 255.
There is but one question before us for decision, and that is the basis upon which petitioner’s losses sustained by reason of storms and worms are to be computed. The pertinent…
2Cases cited4 opinions
- United States v. FlannerySupreme Court of the United States · 1925
- McCaughn v. LudingtonSupreme Court of the United States · 1925
- Goodrich v. EdwardsSupreme Court of the United States · 1921
- Walsh v. BrewsterSupreme Court of the United States · 1921
3Cited by7 opinions
- Grant v. CommissionerUnited States Board of Tax Appeals · 1934
- Louis v. CommissionerUnited States Board of Tax Appeals · 1934
- Grant v. CommissionerUnited States Board of Tax Appeals · 1934
- Jackson v. CommissionerUnited States Tax Court · 1954
- Kraus v. CommissionerUnited States Tax Court · 1951
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