Opinion · United States Board of Tax Appeals
Hummel-Ross Fibre Corp. v. Commissioner
Hummel-Ross Fibre Corp. v. Comm’r, 31 B.T.A. 451 (B.T.A. 1934)
- Type
- Opinion
- Court
- United States Board of Tax Appeals
- Jurisdiction
- Federal
- Date
- 1934-10-30
- Topic
- international-arbitration
Mtjedock, dissenting: I think the determination of the Commissioner that the bonds were sold at par and nothing was received for the stock should be approved because the petitioner has failed to introduce evidence from which the Board can determine how much was paid for the' bonds and how much was paid for the stock. Where a guess is the only alternative to an affirmance of the Commissioner’s determination, the determination should be approved.
Citator
UpLaw has not yet analyzed Hummel-Ross Fibre Corp. v. Commissioner. The absence of a flag is not a finding that it is good law.
dissenting: I think the determination of the Commissioner that the bonds were sold at par and nothing was received for the stock should be approved because the petitioner has failed to introduce evidence from which the Board can determine how much was paid for the' bonds and how much was paid for the stock. Where a guess is the only alternative to an affirmance of the Commissioner’s determination, the determination should be approved.