Blum's, Inc. v. Commissioner
United States Board of Tax Appeals
1. A person who regularly sells or otherwise disposes of personal property on the installment plan is entitled, under the provisions of section 1208 of the Revenue Act of 1926, in computing income under the Revenue Acts of 1916, 1917, 1918, 1921, and 1924, to return the income from installment sales by the use of the installment method as prescribed by subdivision (d) of section 212 of the Revenue Act of 1926. 2. A taxpayer who changes from the straight accrual method to the…
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1. A person who regularly sells or otherwise disposes of personal property on the installment plan is entitled, under the provisions of section 1208 of the Revenue Act of 1926, in computing income under the Revenue Acts of 1916, 1917, 1918, 1921, and 1924, to return the income from installment sales by the use of the installment method as prescribed by subdivision (d) of section 212 of the Revenue Act of 1926. 2. A taxpayer who changes from the straight accrual method to the installment sales method of returning income must return as income of the year in which the change is made, and of all…
1Opinion of the Court
*750OPINION.
Littleton:
Petitioner moved to dismiss the Commissioner’s amended answer on the grounds that it was not really an answer in the case as originally made by the appeal, and had no relation to the deficiencies originally asserted and appealed from; that the amended answer did not meet any issue raised in the petition but amounted in substance to the institution of an entirely new case; that its effect was to assess new deficiencies without giving the petitioner the 60-day notice authorized by the statute and affording it an opportunity to appeal in the regular way; that the Commissioner…
2Cases cited1 opinion
- United States v. MitchellSupreme Court of the United States · 1926
3Cited by19 opinions
- Ludlow v. CommissionerUnited States Tax Court · 1961
- Jackson Furniture Co. v. McLaughlinCourt of Appeals for the Ninth Circuit · 1936
- Marcor, Inc. v. CommissionerUnited States Tax Court · 1987
- W. T. Grant Co. v. CommissionerUnited States Tax Court · 1972
- Marshall v. United StatesDistrict Court, S.D. California · 1939
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