Web10. For discussion of these problems, see Brown v. Helvering, 291 U.S. 193 (1934); South Dade Farms v. Commissioner, 138 F.2d 818 (5th Cir. 1943); Seghers, ... Helvering v. Taylor, 293 U.S. 507 (1934). The Commissioner's determina-tion is prima facie correct. RULES OF PRACTICE BEFORE THE TAX COURT OF THE U.S., Rule 32 (1948). WebWiener, 279 U.S. 333, 49 S.Ct. 337, 73 L.Ed. 720; Helvering v. Independent Life Insurance Co., 292 U.S. 371 , 54 S.Ct. 758, 78 L.Ed. 1311. The exigencies of a tax determined on an annual basis may lead to the inclusion as income of items which might be shown to involve no gain if the transactions were viewed as a whole over several years.
Brown v. Helvering, 291 U.S. 193 - courtlistener.com
WebSee Brown v. Helvering, 291 U.S. 193 , where these two problems were involved and were treated as distinct. The collection of taxes clearly should not be made to depend on the vicissitudes of litigation with third parties in which the taxpayer may be engaged. That is quite a different thing, however, from holding that the Commissioner may force ... WebBROWN v. HELVERING. 291 U.S. 193 (1934) CERTIORARI TO THE CIRCUIT COURT OF APPEALS FOR THE NINTH DISTRICT. No. 187. Argued December 13, 14, … philo farnsworth warehouse 13
THE TREATMENT OF CONTINGENT LIABILITIES IN TAXABLE …
WebIn Brown v. Helvering, 291 U.S. 193, 54 S. Ct. 356, 361, 78 L.Ed. 725 (1934), the Court stated that the Commissioner is vested with "a wide discretion in deciding whether to … WebWe cannot say, in the circumstances here, that the discretionary action of the Commissioner, sustained by both the Tax Court and the Court of Appeals, exceeded permissible limits. See Brown v. Helvering, 291 U.S. 193, 204-205, 54 S.Ct. 356, 361, 78 L.Ed. 725." [Emphasis supplied.] Webv. Burnet. It was then promptly applied in Brown v. Helvering,' ' Beginning with the Revenue Act of 1916, taxpayers were permitted to return in-come using the method of accounting with which their accounts were kept. Revenue Act of 1916, ch. 463, § 8(g), 39 Stat. 763 (individuals), and § x3 (d), 39 Stat. 771 philofest