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.

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.