Hoey v. Commissioner

SteRNHageN :

The petitioner sold his laundry business in 1922 for $200,000 and in his tax return he included no part thereof, on the theory that the price was not in excess of its value on March 1, 1913. The deficiency letter is not before us, but we are told that the Commissioner regarded part of the sale price as gain and so determined the deficiency of something over $28,000. The petitioner now contends that the business assets had a certain value on March 1, 1913, including a value for good will and a value for buildings. But there is nothing in the record which attains the dignity of…