Appeal of Valley Steamship Co.
Cases that cite this one
2 later published cases cite this decision.
- Philadelphia Steel & Iron Corp. v. Commissioner (United States Tax Court 1964)
- Valley S.S. Co. v. Commissioner (United States Board of Tax Appeals 1925)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion of the Court
This appeal and the Appeal of The Kinsman Transit Co., 1 B. T. A. 552, are almost identical. The counsel for the taxpayer was the same in each instance. In that appeal it was clearly pointed out that value was a question of fact and that it could not Jbe proven by formulae alone. A formula without some facts to which to apply it is useless. There is not in the record in this appeal a single fact upon which we could base a determination of value. No witness has testified to the actual value on March 1, 1913. The evidence contains no statement as to cost or date of construction. We do not even know the valuation fixed by the Commissioner, and yet we are asked to hold that such valuation is erroneous because the Commissioner used a flat, instead of a progressive, depreciation rate.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.