Bar L Ranch Inc. v. Phinney

DYER, Circuit Judge. In reporting the amount of capital gain realized in a transaction in which it received a note and accounts receivable having a combined face value of $118,100.07, taxpayer valued the note and accounts at substantially below their face. The Commissioner of Internal Revenue determined they should be valued at their face value. The District Court found that the taxpayer failed to show the incorrectness of the Commissioner's assessment and the correct value upon which the tax should have been assessed and entered judgment for the Government. We reverse and remand.