United States Board of Tax Appeals July 18, 1930, Docket No. 39712. (Dime Bank of Lansford v. Commissioner)

lead-opinion

*251OPINION.

Black :

The burden of proof in this case is upon the petitioner to show that the respondent erred in his determination. It was the contention of petitioner in its original petition that it purchased the deposit accounts of John Shigo for $20,000, and that as part of the transaction Shigo “ delivered over the accounts of his depositors and personally attended to the