Roche v. Commissioner
United States Board of Tax Appeals
1. Held that the Board has jurisdiction to hear and determine the issues presented under section 280. 2. The amount of the liability of the petitioner as a transferee determined from the evidence. 3. Held, further, under the facts presented that the period of limitation for proceeding against the transferee as to the years 1919 and 1920 had expired. 4. Held, further, that the petitioner has failed to introduce sufficient evidence to overcome the presumption of correctness of…
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1. Held that the Board has jurisdiction to hear and determine the issues presented under section 280. 2. The amount of the liability of the petitioner as a transferee determined from the evidence. 3. Held, further, under the facts presented that the period of limitation for proceeding against the transferee as to the years 1919 and 1920 had expired. 4. Held, further, that the petitioner has failed to introduce sufficient evidence to overcome the presumption of correctness of the Commissioner's determination of the amount of tax liability of the taxpayer.
1Opinion of the Court
FRANK L. ROCHE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Roche v. Commissioner
Docket No. 21556.
United States Board of Tax Appeals
21 B.T.A. 1139; 1931 BTA LEXIS 2239;
January 14, 1931, Promulgated
1. Held that the Board has jurisdiction to hear and determine the issues presented under section 280.
2. The amount of the liability of the petitioner as a transferee determined from the evidence.
3. Held, further, under the facts presented that the period of limitation for proceeding against the transferee as to the years 1919 and 1920 had expired.
4. Held, further, that the petitioner…
2Cases cited1 opinion
- Roche v. CommissionerUnited States Board of Tax Appeals · 1931