Warren Jones Co. v. Commissioner
United States Tax Court
In a case involving the year of sale, 1968, this Court entered a decision based on an agreed-upon computation of the parties which was not considered by the Court. Warren Jones Co. v. Commissioner, 60 T.C. 663 (1973). That computation was wrong.
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In a case involving the year of sale, 1968, this Court entered a decision based on an agreed-upon computation of the parties which was not considered by the Court. Warren Jones Co. v. Commissioner, 60 T.C. 663 (1973). That computation was wrong. Held, collateral estoppel is not applicable to require that the erroneous method of computation of the parties for the year 1968 be used in computing the amount of capital gain on the sale that must be included in taxpayer's income for the years 1969 and 1970.
1Opinion of the Court
OPINION
Drennen, Judge:
Respondent determined deficiencies in petitioner’s corporate income taxes for the taxable years ended October 31, 1969, and October 31, 1970, in the amounts of $1,936.98 and $668.66, respectively. One adjustment giving rise to the deficiencies has been conceded by petitioner. The principal issue presently in dispute is whether, in computing the gross profit percentage for an installment sale, the doctrine of collateral estoppel binds respondent to a stipulated computation for entry of decision incorporated in our decision in Warren Jones Co. v. Commissioner, 60 T.C. 663…
2Cases cited13 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Tait v. Western Maryland Railway Co.Supreme Court of the United States · 1933
- United States v. International Building Co.Supreme Court of the United States · 1953
- United States v. Stone & Downer Co.Supreme Court of the United States · 1927
- Jefferson v. CommissionerUnited States Tax Court · 1968
8 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Calcutt v. CommissionerUnited States Tax Court · 1988
- Estate of Silverman v. CommissionerUnited States Tax Court · 1992
- Warren Jones Co. v. CommissionerCourt of Appeals for the Ninth Circuit · 1980
- Calcutt v. CommissionerUnited States Tax Court · 1988
- Estate of Silverman v. CommissionerUnited States Tax Court · 1992
5 more not listed; retrieve them via the Exa API.