# Cook v. Commissioner

> United States Board of Tax Appeals · June 23, 1925 · 2 B.T.A. 126

URL: https://www.frixlaw.com/law-library/cases/4490553

## Case

- **Full name:** APPEAL OF CLIFFORD A. COOK, OF THE WILL OF CHARLES A. CLAFLIN.
- **Court:** United States Board of Tax Appeals
- **Decided:** June 23, 1925
- **Citations:** 2 B.T.A. 126; 1925 BTA LEXIS 2536
- **Precedential status:** Published
- **Opinion:** Opinion of the court by Green
- **Judges:** Lansdon, Green, Grautner
- **Cited by:** 5 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4490553

## Opinion text

*127 OPINION.
Green:
The evidence includes the taxpayer’s valuation, the Commissioner’s valuation, the appraisement for the Massachusetts inheritance tax, the appraisement for local tax purposes, and the opinions of several witnesses, as well as evidence as to sales of like property.
Certain witnesses testified that in their opinion a fractional interest in real estate, though that fraction be more than half, is worth less than the same fractional part of the total value. There is nothing in the record to indicate that there are in this case any special conditions which reduce the value of a fractional part, or that the value of the fractional part is less than the proportionate part of the value of the whole.
From the evidence before us, we are of the opinion that the correct value of the nine-fourteenths interest in the trust held by the estate is $101,442.85.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4490553. Public record. Not legal advice.