Sturgess v. Commissioner
United States Board of Tax Appeals
1. Representatives of taxpayers are presumed to know the rules of evidence, and where, in the trial of an appeal, it develops that taxpayer's evidence is incompetent, the Board, out of deference to the interests of appellants in pending cases, will not grant a continuance to enable taxpayer to produce necessary witnesses, but will dispose of the appeal on the allegations of the petition admitted by the Commissioner. 2. The value of shares of stock in a corporation may not be…
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1. Representatives of taxpayers are presumed to know the rules of evidence, and where, in the trial of an appeal, it develops that taxpayer's evidence is incompetent, the Board, out of deference to the interests of appellants in pending cases, will not grant a continuance to enable taxpayer to produce necessary witnesses, but will dispose of the appeal on the allegations of the petition admitted by the Commissioner. 2. The value of shares of stock in a corporation may not be established by an ex parte report of an appraisal of its assets, not identified or explained by the corporation's…
1Opinion of the Court
OPINION.
Lansdon:
This appeal presents several features of interest to the public. The taxpayer appeals from a determination of the Commissioner as to the value of certain stocks owned by the decedent, Lucy H. Sturgess, at the date of her death. The taxpayer alleges that the Commissioner erred in his determination of such value and asserts that, as a matter of fact, the securities were worth much less than the amount found by the Commissioner.
The only issue involved is a question of fact. The Commissioner having determined a valuation for the assessment of the estate tax, *71the taxpayer must…
2Cited by5 opinions
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- Estate of Shafer v. CommissionerUnited States Tax Court · 1983
- Pierce v. CommissionerUnited States Board of Tax Appeals · 1931
- Sturgess v. CommissionerUnited States Board of Tax Appeals · 1925