Hutton v. Commissioner
United States Board of Tax Appeals
The Commissioner has successfully borne the burden of proof cast upon him to show that a petitioner is liable as a transferee of property of a taxpayer if he makes a prima facie case which is not answered or rebutted by the petitioner.
1Opinion of the Court
*102OPINION.
MuRdock :
The petitioner waived one allegation of error, and the parties stipulated that an adjustment should be made in regard to the inventory on December 81, 1920. In the recomputation under Rule 50 this agreed adjustment shall be given effect.
Section 602 of the Revenue Act of 1928 amended Title IX of the Revenue Act of 1924, as amended, by adding to the end thereof two new sections under the heading “ Transferee Proceedings.” The first section is as follows:
Seo. 912. In proceedings before the Board the burden of proof shall be upon the Commissioner to show that a petitioner is…
2Cited by13 opinions
- Robinette v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
- Mendelson v. Comm'rUnited States Tax Court · 1969
- Baker v. CommissionerUnited States Board of Tax Appeals · 1934
- Alonso v. CommissionerUnited States Tax Court · 1982
- Frank E. Sellers, Transferee of the Assets of Norpaco Builders, Inc., Transferor v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1979
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