Marcor, Inc. v. Commissioner
United States Tax Court
Ward, a member of P's consolidated group, is an accrual basis taxpayer which reports its income from installment credit sales pursuant to the provisions of sec. 453, I.R.C. 1954. Ward is a dealer in personal property which sells merchandise at retail through its mail order catalogs and department stores. Some of the merchandise Ward sells requires installation or "preparation" (e.g., assembly, alteration) prior to its use by the customer.
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Ward, a member of P's consolidated group, is an accrual basis taxpayer which reports its income from installment credit sales pursuant to the provisions of sec. 453, I.R.C. 1954. Ward is a dealer in personal property which sells merchandise at retail through its mail order catalogs and department stores. Some of the merchandise Ward sells requires installation or "preparation" (e.g., assembly, alteration) prior to its use by the customer. Ward provides installation and preparation services to the customer for its merchandise, though all merchandise may be purchased without installation or…
1Opinion of the Court
Marcor, Inc., and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent
Marcor, Inc. v. Commissioner
Docket Nos. 13037-82, 29876-82
United States Tax Court
89 T.C. 181; 1987 U.S. Tax Ct. LEXIS 106; 89 T.C. No. 16;
July 27, 1987; As amended August 28, 1987 July 27, 1987, Filed
Ward, a member of P's consolidated group, is an accrual basis taxpayer which reports its income from installment credit sales pursuant to the provisions of sec. 453, I.R.C. 1954. Ward is a dealer in personal property which sells merchandise at retail through its mail order catalogs and department stores.…
2Cases cited17 opinions
- Federal Land Bank of St. Paul v. Bismarck Lumber Co.Supreme Court of the United States · 1941
- First Agricultural National Bank of Berkshire County v. State Tax CommissionSupreme Court of the United States · 1968
- Blair v. Oesterlein MacHine Co.Supreme Court of the United States · 1927
- Helvering v. Cement Investors, Inc.Supreme Court of the United States · 1942
- Laurence M. And Phyllis W. Carlson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
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