United States Board of Tax Appeals August 25, 1927, Docket No. 4645. (Elken v. Commissioner)

lead-opinion

*1161OPINION.

Smith:

The respondent determined the deficiency in this case upon the theory that the sale took place on March 1, 1920, and that there was a down payment of $10,000 which was in excess of 25 per cent of the selling price.