Legal Opinion

Pacific Vegetable Oil Corp. v. Commissioner

United States Tax Court

Decided April 5, 1956No. Docket No. 50344Published

1. Held, the revision effected by petitioner in 1949 to reflect contract sales accounts under which 95 per cent payments had been made in 1949 and for which contingent adjustments might be made in 1950 upon the determination in 1950 of certain facts constituted a change in its accrual method of accounting for which prior consent of the Commissioner was required.

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1. Held, the revision effected by petitioner in 1949 to reflect contract sales accounts under which 95 per cent payments had been made in 1949 and for which contingent adjustments might be made in 1950 upon the determination in 1950 of certain facts constituted a change in its accrual method of accounting for which prior consent of the Commissioner was required. Held, further, that respondent's action in rejecting the change and his requirement that the method of accounting employed by petitioner prior to 1949 be continued, is not proven to be arbitrary or an abuse of the Commissioner's…

1Opinion of the Court

Pacific Vegetable Oil Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Pacific Vegetable Oil Corp. v. Commissioner

Docket No. 50344

United States Tax Court

26 T.C. 1; 1956 U.S. Tax Ct. LEXIS 224;

April 5, 1956, Filed

Decision will be entered for the respondent.

1. Held, the revision effected by petitioner in 1949 to reflect contract sales accounts under which 95 per cent payments had been made in 1949 and for which contingent adjustments might be made in 1950 upon the determination in 1950 of certain facts constituted a change in its accrual method of accounting for which…

2Cases cited25 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  3. Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
  4. Brown v. HelveringSupreme Court of the United States · 1934
  5. Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944

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