Legal Opinion

Arden-Rayshine Co. v. Commissioner

United States Board of Tax Appeals

Decided January 14, 1941No. Docket No. 100156Published

Petitioner during 1936 received from certain of its vendors refunds representing that portion of amounts paid to such vendors in the purchase of cotton cloth as was attributable to the processing tax on the cotton used in the manufacture of the cloth and respondent has determined that petitioner is liable for the tax imposed by section 501(a)(2) on the net income from such refunds.

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Petitioner during 1936 received from certain of its vendors refunds representing that portion of amounts paid to such vendors in the purchase of cotton cloth as was attributable to the processing tax on the cotton used in the manufacture of the cloth and respondent has determined that petitioner is liable for the tax imposed by section 501(a)(2) on the net income from such refunds. Held that petitioner, though not limited to any particular form of proof, must establish by adequate proof the facts essential to its defense against such tax; held, further, that the proof of record does not show…

1Opinion of the Court

ARDEN-RAYSHINE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Arden-Rayshine Co. v. Commissioner

Docket No. 100156.

United States Board of Tax Appeals

43 B.T.A. 314; 1941 BTA LEXIS 1521;

January 14, 1941, Promulgated

Petitioner during 1936 received from certain of its vendors refunds representing that portion of amounts paid to such vendors in the purchase of cotton cloth as was attributable to the processing tax on the cotton used in the manufacture of the cloth and respondent has determined that petitioner is liable for the tax imposed by section 501(a)(2) on the net income…

2Cases cited1 opinion

  1. Arden-Rayshine Co. v. CommissionerUnited States Board of Tax Appeals · 1941

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