Cunningham v. Commissioner

Appeal of S. A. CUNNINGHAM.

Cunningham v. Commissioner

Docket No. 275.

United States Board of Tax Appeals

1 B.T.A. 177; 1924 BTA LEXIS 233;

December 11, 1924, decided Submitted December 1, 1924.

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Taxpayer's deficiency in tax for the year 1920 determined at $1,761.27.

George M. Morris, Esq., for the taxpayer.

Arthur H. Fast, Esq. (Nelson T. Hartson, Solicitor of Internal Revenue) for the Commissioner.

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Before JAMES, STERNHAGEN, and TRAMMELL.

FINDINGS OF FACT.

This appeal came on for hearing on November 13, 1924, at which hearing it appeared that the only issues in the case were questions of fact comparatively easy of solution by both the taxpayer and the Commissioner.

By consent of both parties a continuance was granted to afford the taxpayer and the Commissioner an opportunity to stipulate the facts and the resulting computation of the deficiency in tax due from the taxpayer for the year 1920.

On December 1, 1924, a stipulation was duly filed with the Board that the correct deficiency in the tax for the year 1920 was $1,761.27.

DECISION.

The Board determines that the amount of the said taxpayer's deficiency for the year 1920 is $1,761.27.