Legal Opinion

Shepard v. Commissioner

United States Board of Tax Appeals

Decided February 27, 1929No. Docket No. 17132Published

1. The taxpayer, without reference to his tax liability, settled through compromise an ad valorem penalty assessment, incurred through the irregular filing of his tax return for the year.

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1. The taxpayer, without reference to his tax liability, settled through compromise an ad valorem penalty assessment, incurred through the irregular filing of his tax return for the year. Held, that such settlement in no way affected his liability to further assessment for any additional taxes later determined for said year. 2. Evidence in support of deductions claimed for losses through investment in corporation stock and for a bad debt held insufficient to show loss sustained within the taxable year.

1Opinion of the Court

STUART G. SHEPARD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Shepard v. Commissioner

Docket No. 17132.

United States Board of Tax Appeals

15 B.T.A. 627; 1929 BTA LEXIS 2812;

February 27, 1929, Promulgated

1. The taxpayer, without reference to his tax liability, settled through compromise an ad valorem penalty assessment, incurred through the irregular filing of his tax return for the year. Held, that such settlement in no way affected his liability to further assessment for any additional taxes later determined for said year.

2. Evidence in support of deductions claimed for losses…

2Cases cited1 opinion

  1. Shepard v. CommissionerUnited States Board of Tax Appeals · 1929

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