Tax

Appeal of F. B. ALVORD

2 B.T.A. 168·United States Board of Tax Appeals·1925

Before James, LittletoN, Smith, and Teussell.

Brief incoming

Hand-reviewed Bluebook brief (procedural posture, facts, issue, holding, reasoning, dissent) ships once the AI generation pipeline runs through this case. Join the waitlist to get notified when 1L briefs go live.

Opinion

Appeal of F. B. ALVORD. Docket No. 2132. Submitted May 28, 1925. Decided June 25, 1925. M. N. Fisher, Esq., for the Commissioner. Before James, LittletoN, Smith, and Teussell. [MAJORITY] This is an appeal from the determination of a deficiency in income tax for the year 1922 in an amount not stated in the petition, but said to be less than $10,000. The taxpayer daims a loss arising from the sale of property. FINDINGS OF FACT. During the year 1900 the taxpayer acquired and thereafter operated a family hotel in East Orange, N. J. During the year 1922 the entire property, including buildings, furnishings, and the good will of the business, was sold for $119,570. The actual cost of the property so disposed of was, to the date of sale, $117,629.42. The depreciated value of the property was $115,203.70 at the time of sale. The March 1, 1913, value of the property, inclusive of good will of the business, was $155,869.30. DECISION. The determination of the Commissioner is approved.