The opinion
Appeal of GIBB INSTRUMENT CO.
Gibb Instrument Co. v. Commissioner
Docket No. 70.
United States Board of Tax Appeals
1 B.T.A. 278 ; 1925 BTA LEXIS 2980 ;
January 8, 1925 , decided Submitted December 15, 1924 .
*2980 The taxpayer is not entitled to relief in the absence of sufficient evidence to establish the allegations asserted in the petition.
J. H. Amick, C.P.A., for the taxpayer.
R. A. Littleton, Esq. (Nelson T. Hartson, Solicitor of Internal Revenue) for the Commissioner.
*278 Before LANSDON, SMITH, and TRAMMELL.
This appeal involves income taxes for the years 1918 and 1919 and is from a deficiency amounting to $849.83 determined by the Commissioner. Neither documentary evidence nor oral testimony was offered in support of the assignments of error enumerated in the petition of the taxpayer, nor was there any stipulation as to the facts involved. Therefore, there is nothing before the Board upon which to base findings of facts.
DECISION.
The taxpayer has failed to present evidence to prove the allegations of its petition. The deficiency determined by the Commissioner is approved.