S. & L. Bldg. Corp. v. Commissioner

L. HAND, Circuit Judge.

The appeal involves the application of section 212 (d) of the Revenue Act of 1926 (26 USCA § 953 (d), which, although the transactions at bar happened in 1924 and 1925, section 1208 of the act (26 USCA § 953a) made retroactive. It was designed to allow a taxpayer in the case of installment sales to spread the profit over the whole peiiod during which payments were made, so as to avoid loading all of it upon those years which followed the amortization of the original cost. It gave a privilege; “the income •may * * * ° bo returned on the basis and in the manner above…