Appeal and Decision No. Terminal Wine Co., 261 Todd, Inc., B. B., 282 Union Metal Mfg. Co., 147 Smithers, Francis J., deceased, 414 United States Trust Co. of N. Y., Executors of United Telephone Co., 171 Walker-Crim Co., Inc., The, 218 Wallach & Mayer, Inc., 124 Warne & Co., Ltd., Fred., 418 Watlington, W. H., 566 Whitney Duplicating Check Co., 388 Whitney-Roth Shoe Co., 173 Winifrede Coal Co., et al., 209 Wood, Emily, Estate of, 350 COURT CASES CITED Case and Citation Benson v. United States, 146 U. S. 332 Brown v. Walker, 161 U. S. 591 Douglas v. Edwards, 298 Fed. 229, 234 Doyle v. Mitchell, 247 U. S. 179 Goldsmith v. United States Board of Tax Appeals, Dist. Col. C. C. Appeals, Docket No. 4257 Joseph Garneau Co. v. Bowers Mason, et al., v. United States, 244 U. S. 362 Mitchell v. McShane Lumber Co., 220 Fed. 78 Moore v. United States, 91 U. S. 270 Page 111 112 98 98 83 54 111 100 87 Oesterlein Machine Co. v. David H. Blair, Commissioner, Dist. Col. S. Ct., E. 44155 .62, 110 O'Shea v. New York, N. Y. C. and St. L. R. Co., 105 United States v. Benowitz, 262 Fed. 223 42 103 United States v. Kimbolt, 117 Fed. 156 Wycoff v. Wagner Typewriter Co., 99 Fed. 158 112 111 ABATEMENT, INDEX (References are to pages.) See CLAIMS IN ABATEMENT. ACCEPTANCE AGREEMENT, See CONSENT AGREEMENT. AMENDED AND SUPPLEMENTAL PLEADINGS, may be filed upon leave, 68. motion to amend answer, 68. motion to amend petition, 69. where right to special assessment asserted at hearing, 69. ANSWER, See AMENDED AND SUPPLEMENTAL PLEADINGS. form, 67. number of copies required to be filed, 68. service, 69. APPEALS TO BOARD OF TAX APPEALS, See ANSWER; CALENDAR ; CLAIMS IN ABATEMENT; claim for abatement in estate tax cases, 40. form and style of papers, 66. lapses when amount of jeopardy assessment paid, 54. prior to notice of deficiency premature, 45. time for, 45. when appeal is at issue, 70. APPEAL WITHIN BUREAU OF INTERNAL REVENUE, See ASSESSMENT LIST; JURISDICTION OF BOARD OF TAX determination of tax distinguished, 52, made by mistake, 53. made subsequent to notice of determination, 55. ASSESSMENT BY MISTAKE, See JURISDICTION OF BOARD OF TAX APPEALS. ASSESSMENT LETTER, acceptance agreement, 29. audit by field agent, 29. protest against findings of, 29. ASSESSMENT LIST, approval by Commissioner, 29. ATTORNEYS, admission to practice, 82. AUDIT, See BUREAU OF INTERNAL REVENUE. cases involving evasion of tax, 36. BALANCE SHEETS, as evidence, 92. BILL OF PARTICULARS, BOARD OF TAX APPEALS, See ADMISSION TO PRACTICE; DETERMINATION BY administrative tribunal, 12. amendments to 1921 law proposed by Secretary of the business hours, 81. court of record, 24. decisions will not be reviewed, 79. divisions sent to the field, 25. functions quasi-judicial, 42. investigation on its own motion, 63. legislative powers, 43. organization, 24. proceedings informal, 16. promulgation of rules of practice, 25. proposed as independent agency in finance committee provision for appointment of members in treasury draft, 13. provision for jurisdiction of Board in treasury draft, 14. BOARD OF TAX APPEALS-Continued. record of Bureau not before it on appeal, 44. records open to public, 23. restriction on practice of members after leaving office, 22. sixty-day letter, 31. term of office of members as proposed in finance commit- written opinion and findings of fact required, 22. BOND, See JEOPARDY ASSESSMENT. BOOK ENTRIES, as evidence, 98. necessity of establishing, 99. prima facie evidence of facts, 90. BRIEFS, as evidence, 92. filing with Income Tax Unit, 39. form of, 74. number of copies required to be filed, 74. BURDEN OF PROOF, on petitioning taxpayer, 91. what constitutes proof of fact, 92. where case submitted without argument, 73. BUREAU OF INTERNAL REVENUE, audit by collector, 27, 35. audit by field agent, 28. audit of consolidated cases, 34. audit of special assessment cases, 35. estate taxes, 37. excess profits taxes. 27. gift taxes, 37. hearings, 30. hearings before Solicitor, 30. office audit, 32. procedure in, 26. procedure in respect to income taxes, 27. sixty-day letter, 31. |