Clifton Mfg. Co. v. Commissioner
United States Tax Court
Interest which, being of doubtful collectibility, was not accrued on books nor reported as income by accrual basis taxpayer, held, taxable in subsequent year when actual payment was received.
1Opinion of the Court
OPINION.
OppeR, Judge:
The interest due petitioner which is the subject matter of this controversy was not accrued on its books nor included in its income tax return for its fiscal year ended March 1934. During the year ended March 1935 the item was entered upon petitioner’s books and the major portion of it allocated to the preceding year, but no change was made in the status of its tax returns. When respondent’s representative attempted to charge petitioner with the income for the 1935 fiscal year, as a result of an investigation subsequently , conducted, petitioner protested and at that time…
2Cited by9 opinions
- New Hampshire Fire Ins. Co. v. CommissionerUnited States Tax Court · 1943
- Losh v. CommissionerUnited States Tax Court · 1943
- Bryant Heater Co. v. CommissionerUnited States Tax Court · 1954
- Clifton Mfg. Co. v. CommissionerUnited States Tax Court · 1942
- Gallo v. CommissionerUnited States Tax Court · 1959
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