Perine v. Commissioner
United States Board of Tax Appeals
1. Expenses incurred by a partnership for experimental work on ideas and devices abandoned as worthless in 1919, allowed as a loss. 2. The Board is without authority to order the Commissioner to honor an agreement between husband and wife authorizing the application of tax credits due one of them to a deficiency of the other.
1Opinion of the Court
*203OPINION.
Arundell:
The proceeding brought by H. B. Perine is based on respondent’s written notice dated May 5, 1927, wherein an over-assessment of $294.51 was found for the year 1918, not arising out of a claim in abatement, and in which no deficiency was asserted for the year 1919. The proceeding brought by petitioner H. B. Perine is, accordingly, dismissed. Cornelius Cotton Mills, 4 B. T. A. 255. This action eliminates the necessity of making any findings of fact or rendering a decision on the issue raised by H. B. Perine as to the propriety of the respondent’s action in disallowing as a bad…
2Cited by10 opinions
- Hart-Bartlett-Sturtevant Grain Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1950
- Don Gilmore and Sue Gilmore v. United StatesUnited States Court of Claims · 1961
- Roebling v. CommissionerUnited States Board of Tax Appeals · 1933
- Mary Marie Eaves v. United StatesCourt of Appeals for the Tenth Circuit · 1970
- Bozek v. CommissionerUnited States Tax Court · 1986
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