Robison v. Commissioner
United States Board of Tax Appeals
1. TRANSFEREE. - Held, petitioner Lester L. Robison not liable as transferee. Petitioner Elmer D. Bryson liable as transferee. 2. INCREASE OF DEFICIENCY. - Section 308(e) of the Act of 1926 gives the Board jurisdiction to increase the deficiency over that determined by the Commissioner, if asserted by the Commissioner before or at the hearing, and the action of the Board in permitting respondent to amend his answer to that effect is not error. 3. LIMITATION. - The burden of…
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1. TRANSFEREE. - Held, petitioner Lester L. Robison not liable as transferee. Petitioner Elmer D. Bryson liable as transferee. 2. INCREASE OF DEFICIENCY. - Section 308(e) of the Act of 1926 gives the Board jurisdiction to increase the deficiency over that determined by the Commissioner, if asserted by the Commissioner before or at the hearing, and the action of the Board in permitting respondent to amend his answer to that effect is not error. 3. LIMITATION. - The burden of proof to establish the plea of limitation is on petitioners and where it is not shown when the return was filed the plea…
1Opinion of the Court
LESTER L. ROBISON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
ELMER D. BRYSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Robison v. Commissioner
Docket Nos. 22184 and 22255.
United States Board of Tax Appeals
22 B.T.A. 395; 1931 BTA LEXIS 2131;
February 26, 1931, Promulgated
1. TRANSFEREE. - Held, petitioner Lester L. Robison not liable as transferee. Petitioner Elmer D. Bryson liable as transferee.
2. INCREASE OF DEFICIENCY. - Section 308(e) of the Act of 1926 gives the Board jurisdiction to increase the deficiency over that determined by the Commissioner, if…
2Cases cited1 opinion
- Robison v. CommissionerUnited States Board of Tax Appeals · 1931