Glassell v. Commissioner of Internal Revenue

FOSTER, Circuit Judge.

The Commissioner of Internal Revenue determined a deficiency of income and profits taxes of $2,156.56 for the taxable years of 1920 and 1921 and assessed petitioner accordingly. On appeal to the Board of Tax Appeals the Commissioner was affirmed, the Board holding that the petitioner had failed to sustain the burden of showing that the assessment was erroneous.

We need not review the evidence in full. It appears that in making his returns petitioner had charged off $30,974.29 as expenses and losses incurred in his farming operations and had reported only the cash received…