Fowler v. Commissioner
United States Board of Tax Appeals
1. Evidence held insufficient to establish gifts by the taxpayer of interests in a joint venture. 2. Claimed loss on sale of stock disallowed in view of lack of evidence to show sales price. 3. Commissioner's application of provisions of section 211(b) of Revenue Act of 1918 approved. Appeal of M. Fowler,1 B.T.A. 1212; Fowler v. United States, 11 Fed. (2d) 895; 16 Fed.
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1. Evidence held insufficient to establish gifts by the taxpayer of interests in a joint venture. 2. Claimed loss on sale of stock disallowed in view of lack of evidence to show sales price. 3. Commissioner's application of provisions of section 211(b) of Revenue Act of 1918 approved. Appeal of M. Fowler,1 B.T.A. 1212; Fowler v. United States, 11 Fed. (2d) 895; 16 Fed. (2d) 925. 4. The evidence does not sustain the allegations of the Commissioner in his answer that the deficiency should be increased over the amount of which he notified the taxpayer in the sixty-day statutory notice.
1Opinion of the Court
APPEAL OF S. L. FOWLER.
Fowler v. Commissioner
Docket No. 5814.
United States Board of Tax Appeals
6 B.T.A. 250; 1927 BTA LEXIS 3563;
February 19, 1927, Promulgated
1. Evidence held insufficient to establish gifts by the taxpayer of interests in a joint venture.
2. Claimed loss on sale of stock disallowed in view of lack of evidence to show sales price.
3. Commissioner's application of provisions of section 211(b) of Revenue Act of 1918 approved. Appeal of M. Fowler,1 B.T.A. 1212; Fowler v. United States, 11 Fed. (2d) 895; 16 Fed. (2d) 925.
4. The evidence does not sustain the allegations of the…
2Cases cited7 opinions
- Basket v. HassellSupreme Court of the United States · 1883
- Allen-West Commission Co. v. GrumblesCourt of Appeals for the Eighth Circuit · 1904
- Lee v. LeeCourt of Appeals for the D.C. Circuit · 1925
- Bowen v. KutznerCourt of Appeals for the Fourth Circuit · 1908
- Fowler v. CommissionerUnited States Board of Tax Appeals · 1927
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