Opinion · Supreme Court of the United States
Helvering v. Taylor
293 U.S. 507
- Type
- Opinion
- Court
- Supreme Court of the United States
- Jurisdiction
- Federal
- Date
- 1935-01-07
- Topic
- general
How later courts describe this case
- holding that, in a proceeding to recover taxes from a non-bankrupt taxpayer, the taxpayer has the burden of proving that his taxes complied with the Internal Revenue Code
- holding that a determination is presumed correct if it has a rational foundation and is not arbitrary and excessive
- holding that the burden of going forward with evidence to establish the amount of a deficiency may shift to the Commissioner where determination is arbitrary and excessive
- holding that the burden of going forward with the evidence shifts to the Commissioner if the taxpayer shows that the notice of deficiency underlying the proceeding is arbitrary
- noting that the burden of proof is on the taxpayer to invalidate the Commissioner’s determination
- explaining that, in a refund suit, if taxpayer fails to prove the amount due, taxpayer may not recover everything owed to him “even though we know that the tax is too high”
- explaining that, in a refund suit, if the taxpayer fails to prove the amount due, the taxpayer may not recover everything owed to him “even though we know that the tax is too high”
- shifting burden of proof to Commissioner when determination shown to be “arbitrary and excessive”
Citator
UpLaw has not yet analyzed Helvering v. Taylor. The absence of a flag is not a finding that it is good law.
- Cited by
- 1283 opinions
Headnotes
- Tax Law — Burden of Proof on Taxpayer The burden of proof is on the taxpayer to show that the Commissioner's determination of a deficiency is invalid.
- Tax Law — Arbitrary Deficiency Determinations Where a taxpayer's evidence shows the Commissioner's deficiency determination to be arbitrary and excessive, the determination may not be enforced merely because the taxpayer failed to establish the correct amount of tax owed; the taxpayer is not bound to pay a tax that confessedly he does not owe unless his evidence was also sufficient to establish the correct amount that lawfully might be charged against him.
- Tax Law — Board of Tax Appeals Jurisdiction The Board of Tax Appeals has jurisdiction to redetermine the correct amount of a deficiency; this jurisdictional provision does not prescribe any rule of evidence or burden of proof requiring the taxpayer, who has shown the determination to be arbitrary and excessive, to also show that he owes nothing or the correct amount legally due. Revenue Act of 1926, § 274(e)
- Tax Law — Taxpayer Return Requirements Statutes requiring the taxpayer to file under oath a return stating gross income and deductions, and to keep records and comply with the Commissioner's rules, do not support the contention that a taxpayer whose evidence shows the Commissioner's determination to be arbitrary and excessive must nevertheless pay the added tax because he has not shown the correct amount due; such requirements tend rather to suggest that taxpayer's returns are correct and may not arbitrarily be set at naught. Revenue Act of 1928, §§ 51(a), 54(a)
- Tax Law — Board of Tax Appeals Rules A rule of the Board of Tax Appeals placing the burden of proof on the petitioner except as to new matter pleaded in the answer does not require the taxpayer to prove not only that a deficiency assessment was arbitrary and wrong but also to show the correct amount. Board of Tax Appeals Rule 30
- Tax Law — Remand by Circuit Courts of Appeals Circuit Courts of Appeals, upon properly reversing determinations of the Board of Tax Appeals, have power, where justice requires, to remand the case for further hearing in the nature of a new trial. Revenue Act of 1926, § 1003(b)
- Tax Law — Effect of Arbitrary Determination The fact that the Commissioner's determination of a deficiency was arbitrarily made may reasonably be deemed sufficient to require the Board of Tax Appeals to set it aside.
- Tax Law — Remedial Purpose of Board Legislation A rule requiring a taxpayer who has shown the Commissioner's determination to be arbitrary and excessive to prove the correct amount of tax or pay the assessment is not consonant with the great remedial purposes of the legislation creating the Board of Tax Appeals.
delivered the opinion of the Court.
The commissioner determined ,a deficiency of $9,156.69 on account of respondent’s 1928 income tax. The Board of Tax Appeals made the same determination. The court held it excessive and that the evidence did not show the correct amount, reversed the order of the board, and remanded the case for further proceedings in accordance with the opinion. 70 F. (2d) 619. The petition for our writ states the question: “ Whether the Circuit Court of Appeals erred in remanding this case to the Board of Tax Appeals for a new hearing on the ground that the Commissioner’s determination of the amount of income was incorrect, although the taxpayer had failed to prove facts from which a correct determination could be made.”
In August, 1927, respondent acquired all the stock of four utilities at a total cost of $96,030, organized a holding company and, October 13, transferred to it all the
In May, 1928, the holding company sold the stock of the four utilities to the Colonial corporation for $194,-930.16. Later in that year the holding company bought or retired all the preferred and paid the taxpayer $99,000 therefor. In his 1928 return he assigned the $96,030 for which he procured the utilities to the preferred stock of the holding company, deducted that amount from the $99,000 received therefor, and reported the difference, $2,970, as the gain derived from the sale. The applicable statutory provisions are contained in Revenue Act of 1928. §§ 111 (a) (d), 112 (b) (3), 113 (a) (6). 45 Stat. 815-19.1
The Commissioner, holding the taxpayer not entitled to charge the cost of all to the preferred, apportioned between the preferred and common. He made his calculation upon the assumption that the cost, in 1927, attributable to the preferred shares bears the same relation to cost of all the shares then acquired as the amount respondent received, in 1928, for the preferred bears to the amount paid the holding company by Colonial corporation for all the utilities shares.2 On that basis, he found that of the total 1927 cost, $96,030, there was chargeable to the preferred only $48,771.16 which deducted from $99,000 received by respondent for the preferred in 1928, leaves $50,228.84 upon which he determined the deficiency of $9,156.69.
The only question for consideration is that stated in the petition for the writ of certiorari. Gunning v. Cooley, 281 U. S. 90, 98. That question in effect assumes, and here it is taken as granted, that the court rightly held the evidence sufficient to require a finding that the commissioner’s apportionment of total cost as between preferred and common stock was unfair and erroneous and that therefore the commissioner’s determination was exces
The commissioner does not contend that, in cases where Circuit Courts of Appeals properly reverse determinations of the board, they are without power to remand for further hearing in the nature of a new trial.3 His contention is that in this case the burden on the taxpayer was not only to prove that the commissioner’s determination is erroneous but to show the correct amount of the tax. In substance he says that, because of the taxpayer’s failure to establish facts on which a fair apportionment may be made, the board’s redetermination at the commissioner’s erroneous figure was valid, and there being no error of law, should have been sustained by the court. And he maintains that, in the absence of error on the part of the board, the court was without power to remand for further hearing.
He cites Revenue Act of 1926, § 274 (e), 44 Stat. 56: “ The Board shall have jurisdiction to redetermine the correct amount of the deficiency even if the amount so redetermined is greater than the amount of the deficiency,
He also cites Revenue Act of 1928, §§51 (a) and 54 (a). 45 Stat. 807, 808. Neither gives any support to his contention. The first requires the taxpayer to make under oath a return stating specifically the amount of his gross income and the amounts of deductions and credits allowed. The other requires the taxpayer to keep such records, render under oath such statements, make such returns, and comply with such rules and regulations as the commissioner may prescribe. These requirements give no support to the commissioner’s contention. They tend rather to suggest that taxpayer’s returns are correct and may not arbitrarily be set at naught.
He also cites Rule 30 adopted by the board: “ The burden of proof shall be upon the petitioner, except as otherwise provided by statute and except that in respect of any new matter pleaded in his answer, it shall be upon the respondent.” But there is nothing in it to suggest intention to require the taxpayer to prove not only that a deficiency assessment laid upon him was arbitrary and wrong but also to show the correct amount. Moreover, the board held the evidence not sufficient to show the
The commissioner cites United States v. Rindskopf, 105 U. S. 418; United, States v. Anderson, 269 U. S. 422, 443; Reinecke v. Spalding, 280 U. S. 227, 232-233. The first of these may be put aside without discussion as having no bearing upon the point here in controversy.. The other two were adequately distinguished by the Circuit Court of Appeals. Each was an action to recover taxes paid. Obviously the burden was on the plaintiff, in order to establish a basis for judgment in his favor, specifically to show not merely that the assessment was erroneous but also the amount to which he was entitled. For like reason the burden is upon the taxpayer to establish the amount of a deduction claimed. Burnet v. Houston, 283 U. S. 223, 227. Helvering v. Independent Life Ins. Co., 292 U. S. 371, 381. New Colonial Co. v. Helvering, 292 U. S. 435, 440.
We find nothing in the statutes, the rules of the board or our decisions that gives any support to the idea that the commissioner’s determination, shown to be without rational foundation and excessive, will be enforced unless the taxpayer proves he owes nothing or, if liable at all, shows the correct amount. While decisions of the lower courts may not be harmonious, our attention has not
Unquestionably the burden of proof is on the taxpayer to show that the commissioner’s determination is invalid. Lucas v. Structural Steel Co., 281 U. S. 264, 271. Wickwire v. Reinecke, 275 U. S. 101, 105. Welch v. Helvering, 290 U. S. 111, 115. Frequently, if not quite generally, evidence adequate to overthrow the commissioner’s finding is also sufficient to show the correct amount, if any, that is due. See, e. g., Darcy v. Commissioner, 66 F. (2d) 581, 585. But, where as in this case the taxpayer’s evidence shows the commissioner’s determination to be arbitrary and excessive, it may not reasonably be held that he is bound to pay a tax that confessedly he does not owe, unless his evidence was sufficient also to establish the correct amount that lawfully might be charged against him. On the facts shown by the taxpayer in this case, the board should have held the apportionment arbitrary and the commissioner’s determination invalid. Then, upon
Affirmed.
“Sec. 111. (a) Except as hereinafter provided in this section, the gain from the sale or other disposition of property shall be the excess of the amount realized therefrom over the basis provided in section 113, and the loss shall be the excess of such basis over the amount realized. . . .
“(d) In the case of a sale or exchange, the extent to which the gain or loss determined under this section shall be recognized for the purposes of this title, shall be determined under the provisions of section 112.
“ Sec. 112. '(b) (3) No gain or loss shall be recognized if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization.
“Sec. 113. (a) The basis for determining the gain or loss from the sale or other disposition of property acquired after February 28, 1913, shall be the cost of such property; except that . . .
“(6) If the property was acquired upon an exchange described in section 112 (b) to (e), inclusive, the basis shall be the same as in
The figures are: X : $96,030 : : $99,000 : $194,930.17. The calculation stated in the opinion of the Board of Tax Appeals is:
§ 1003 (b), Revenue Act of 1926, 44 Stat. 110, 26 TJ. S. C. Supp. VII, § 641 (c) (1) provides: “Upon such review, such courts shall have power to affirm or, if the decision of the Board is not in accordance with law, to modify or to reverse the decision of the Board, with or without remanding the case for a rehearing, as justice may require.”
The Commissioner cites: Hubinger v. Commissioner, 36 F. (2d) 724. Sanderson v. Commissioner, 42 F. (2d) 160. Autosales Corp. v. Commissioner, 43 F. (2d) 931. Onondaga Co. v. Commissioner, 50 F. (2d) 397. Darcy v. Commissioner, 66 F. (2d) 581, 585. Saxman Coal & Coke Co. v. Commissioner, 43 F. (2d) 556. Williams v. Commissioner, 45 F. (2d) 61. Alexander Sprunt & Son v. Commissioner, 64 F. (2d) 424. Atlantic Bank & Trust Co. v. Commissioner, 59 F. (2d) 363. Lightsey v. Commissioner, 63 F. (2d) 254. Matern v. Commissioner, 61 F. (2d) 663. Atlanta Casket Co. v. Rose, 22 F. (2d) 800. Becker v. United States, 21 F. (2d) 1003.
Cf. Collin v. Commissioner, 32 F. (2d) 753. Citrus Soap Co. v. Lucas, 42 F. (2d) 372. Russell v. Commissioner, 45 F. (2d) 100, 103. Strother v. Commissioner, 55 F. (2d) 626, 632. And see, involving deduction, Underwood v. Commissioner, 56 F. (2d) 67, 72.
House Report No. 179, p. 7; Senate Report No. 398, pp. 8-9, 68th Congress, 1st session. Warren Mfg. Co. v. Tait, 60 F. (2d) 982, 984. Old Colony Trust Co. v. Commissioner, 279 U. S. 716, 721.