Alvord v. Commissioner

APPEAL OF F. B. ALVORD.

Alvord v. Commissioner

Docket No. 2132.

United States Board of Tax Appeals

2 B.T.A. 168; 1925 BTA LEXIS 2519;

June 25, 1925, Decided Submitted May 28, 1925.

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M. N. Fisher, Esq., for the Commissioner.

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Before JAMES, LITTLETON, SMITH, and TRUSSELL.

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 claims 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.