Tanner Oil Co. v. Commissioner

opinion.

Lansdon :

The respondent has asserted a deficiency in income and excess-profits tax for the-year 1919 in the amount of $85,690.34, and in addition has determined a penalty for fraud of $42,845.17. At the hearing counsel for the petitioner stated that he did not desire to press his appeal and conceded the tax liability. The respondent has assumed his burden of proof as to the existence of fraud, which is the only issue in this proceeding.

The petitioner is an Oklahoma corporation, organized in 1912 to engage in the production of and operation for oil and gas. As of December 31, 1918, it…