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A bank stock statement cannot alone establish undervaluation of closing stock for tax purposes without independently verified evidence. Where the taxpayer consistently applied its valuation method, reconciled differences from bank figures, and the books showed no defects, deletion of the addition was upheld. Applying the principle of consistency, deletion of interest disallowance on unpaid purchase price was sustained because no distinguishing facts or evidence of related-party payment or unreasonable interest emerged. Deletion of Keyman Insurance Policy premium disallowance was also upheld, as the company was the policy beneficiary and earlier-year treatment was followed. The tax appeal was dismissed for absence of a substantial question of law.
A bank stock statement cannot alone establish undervaluation of closing stock for tax purposes without independently verified evidence. Where the taxpayer consistently applied its valuation method, reconciled differences from bank figures, and the books showed no defects, deletion of the addition was upheld. Applying the principle of consistency, deletion of interest disallowance on unpaid purchase price was sustained because no distinguishing facts or evidence of related-party payment or unreasonable interest emerged. Deletion of Keyman Insurance Policy premium disallowance was also upheld, as the company was the policy beneficiary and earlier-year treatment was followed. The tax appeal was dismissed for absence of a substantial question of law.
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