Parker v. Commissioner
United States Board of Tax Appeals
1. The Commissioner included interest from certain obligations of the United States in the decedent's taxable income for the year 1921. Held, that the Commissioner did not err in so doing, the obligations not being particularly described in the record nor the date of their issue shown, and that the interest thereon was exempt by virtue of the provisions of section 213(b)(4) of the Revenue Act of 1921. 2. For services rendered in the matter of consolidating certain businesses…
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1. The Commissioner included interest from certain obligations of the United States in the decedent's taxable income for the year 1921. Held, that the Commissioner did not err in so doing, the obligations not being particularly described in the record nor the date of their issue shown, and that the interest thereon was exempt by virtue of the provisions of section 213(b)(4) of the Revenue Act of 1921. 2. For services rendered in the matter of consolidating certain businesses and the organization of a corporation to effect such result, the decedent paid $10,000, and in computing net taxable…
1Opinion of the Court
*1244OPINION.
Seawell :
The deficiencies in income tax as determined by the respondent and contested by the petitioner are for the years 1921 to 1926, both inclusive. In each of the three dockets involved numerous errors are assigned, raising many issues for our determination.
*1245One issue, applicable to all the years involved, is the question of fraud, the respondent having asserted penalties in each of the years on the ground that there was no bona fide five-party partnership and that the decedent made false and fraudulent returns on the assumption that such partnership was bona fide, and did so to…
2Cases cited1 opinion
- Surety Finance Co. of Tacoma v. CommissionerUnited States Board of Tax Appeals · 1933
3Cited by1 opinion
- Parker v. CommissionerUnited States Board of Tax Appeals · 1934