McDaniel v. Commissioner
United States Tax Court
Petitioner, under section 29.22(c)-6 of Regulations 111, elected to change the basis of his return for the year 1947 from that of cash receipts and disbursements used in prior years to an inventory basis. Petitioner, a farmer, has the right to make such change without securing the formal permission of the Commissioner provided he complies with the regulations.
Read the full summary
Petitioner, under section 29.22(c)-6 of Regulations 111, elected to change the basis of his return for the year 1947 from that of cash receipts and disbursements used in prior years to an inventory basis. Petitioner, a farmer, has the right to make such change without securing the formal permission of the Commissioner provided he complies with the regulations. Held, petitioner did not comply with the applicable regulations and the Commissioner is sustained in refusing to recognize his right to use an accrual basis. Kenneth S. Battelle, 9 T. C. 299, distinguished.
1Opinion of the Court
A. J. McDaniel, Petitioner, v. Commissioner of Internal Revenue, Respondent
McDaniel v. Commissioner
Docket No. 31507
United States Tax Court
19 T.C. 474; 1952 U.S. Tax Ct. LEXIS 15;
December 18, 1952, Promulgated
Decision will be entered for the respondent.
Petitioner, under section 29.22(c)-6 of Regulations 111, elected to change the basis of his return for the year 1947 from that of cash receipts and disbursements used in prior years to an inventory basis. Petitioner, a farmer, has the right to make such change without securing the formal permission of the Commissioner provided he complies with…
2Cases cited2 opinions
- Battelle v. CommissionerUnited States Tax Court · 1947
- McDaniel v. CommissionerUnited States Tax Court · 1952