Legal Opinion
City Gas Company of Florida v. Commissioner of Internal Revenue
Court of Appeals for the Eleventh Circuit
Decided October 21, 1982No. 80-5882PublishedCited by 26 opinions
1Opinion of the Court
R. LANIER ANDERSON, III, Circuit Judge:
The Commissioner of Internal Revenue brings this appeal from adverse judgments entered by the Tax Court of the United States. The sole issue on appeal is whether certain deposits paid by customers upon the opening of new accounts are includable in appellees’ gross income. The Tax Court held that these deposits were not income. City Gas Co. of Florida v. Commissioner, 74 T.C. 386 (1980). After reviewing the applicable case law, however, we conclude that deposits of this nature are income if the primary purpose of the deposit is to act as a prepayment of…
2Cases cited17 opinions
- Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
- Gilken Corporation v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1949
- Gilken Corp. v. CommissionerUnited States Tax Court · 1948
12 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Commissioner v. Indianapolis Power & Light Co.Supreme Court of the United States · 1990
- American Medical Association, Cross-Appellant v. United States of America, Cross-AppelleeCourt of Appeals for the Seventh Circuit · 1989
- Illinois Power Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
- John F. Knowlton and Betty F. Knowlton v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1986
- Iowa Southern Utilities Company and Subsidiary Companies v. The United StatesCourt of Appeals for the Federal Circuit · 1988
21 more not listed; retrieve them via the Exa API.