Schneider v. Commissioner
United States Tax Court
Petitioners owned the stock of Raybert Productions, Inc. (Raybert), which, in turn, owned a motion picture named "Easy Rider" and a television program known as "The Monkees."
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Petitioners owned the stock of Raybert Productions, Inc. (Raybert), which, in turn, owned a motion picture named "Easy Rider" and a television program known as "The Monkees." Raybert had a distribution contract entitling it to payments from Columbia Pictures Industries, Inc., based upon monthly accounting periods with respect to "Easy Rider," and a similar contract with respect to "The Monkees" entitling it to annual payments on Nov. 30 from Screen Gems, Inc., for each fiscal year ending July 23. On May 23, 1970, Raybert was liquidated, and its assets were distributed to petitioners. Held,…
1Opinion of the Court
OPINION
1. Allocation of Income under Section 446
The cash receipts and disbursements method of accounting used by Raybert is one of the acceptable accounting methods prescribed by section 446(c).5 Since the payments under “Easy Rider” statements Nos. 9 and 10 and “The Monkees” annual statement for the year ended July 23, 1970, had not been received when Raybert was liquidated on May 23, 1970, petitioners did not include those payments in the corporation’s final taxable period. Respondent argues that prior to its liquidation, Raybert had “earned” the full amount of the payment on “Easy Rider”…
2Cases cited40 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Burnet v. LoganSupreme Court of the United States · 1931
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
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3Cited by27 opinions
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