1927 BTA LEXIS 2541 | B.T.A. | 1927
Lead Opinion
OPINION.
We are unable to determine from the record either the cost or the March 1,1913, value of the assets which were destroyed by fire in 1920. The facts submitted are meagre and the testimony of the treasurer of the petitioner corporation, the sole witness at the hearing, is confusing and conflicting.
The petitioner in arriving at the alleged loss of $9,160.38, stated that it used as a basis one-half of the 1920 replacement value of the plant as representing a March 1, 1913, value and deducted
The burden of proof is on the petitioner to submit such evidence as will enable us to decide that the determination of the respondent is incorrect. This the petitioner has wholly failed to do.
Judgment will be entered for the respondent.