Schniers v. Commissioner
United States Tax Court
Held, petitioners did not constructively receive income in 1973 from the sale of their cotton in that year but realized income in 1974 when they were actually paid for it. Held, further, the gin with which petitioner dealt in selling the cotton was the purchaser's agent, not petitioner's agent, in handling the transaction.
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Held, petitioners did not constructively receive income in 1973 from the sale of their cotton in that year but realized income in 1974 when they were actually paid for it. Held, further, the gin with which petitioner dealt in selling the cotton was the purchaser's agent, not petitioner's agent, in handling the transaction. Held, further, petitioner's sale of cotton grown in 1973 under agreements calling for him to be paid for such cotton in 1974 did not constitute a change in his method of accounting or a distortion of his 1973 income.
1Opinion of the Court
Charles B. Schniers and Dorothy M. Schniers, Petitioners v. Commissioner of Internal Revenue, Respondent
Schniers v. Commissioner
Docket No. 10225-75
United States Tax Court
69 T.C. 511; 1977 U.S. Tax Ct. LEXIS 2;
December 27, 1977, Filed
Decision will be entered under Rule 155.
Held, petitioners did not constructively receive income in 1973 from the sale of their cotton in that year but realized income in 1974 when they were actually paid for it. Held, further, the gin with which petitioner dealt in selling the cotton was the purchaser's agent, not petitioner's agent, in handling the transaction.…
2Cases cited16 opinions
- Helvering v. OwensSupreme Court of the United States · 1939
- Commissioner of Internal Revenue v. OatesCourt of Appeals for the Seventh Circuit · 1953
- Veit v. CommissionerUnited States Tax Court · 1947
- Amend v. CommissionerUnited States Tax Court · 1949
- Cowden v. CommissionerCourt of Appeals for the Fifth Circuit · 1961
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