Ireland v. Commissioner
United States Tax Court
Petitioners' original return for the year 1955 did not report on the installment basis the sale of a skating rink or disclose said sale in any manner, and the return did not include any payments received by the petitioners in 1955 from such sale. Held, the petitioners may not elect, under section 453 of the Internal Revenue Code of 1954, to report the sale on the installment basis in an amended return for 1955 filed by them in 1957.
1Opinion of the Court
W. A. Ireland and Lorrene B. Ireland, Petitioners, v. Commissioner of Internal Revenue, Respondent
Ireland v. Commissioner
Docket No. 73412
United States Tax Court
32 T.C. 994; 1959 U.S. Tax Ct. LEXIS 112;
July 31, 1959, Filed
Decision will be entered under Rule 50.
Petitioners' original return for the year 1955 did not report on the installment basis the sale of a skating rink or disclose said sale in any manner, and the return did not include any payments received by the petitioners in 1955 from such sale. Held, the petitioners may not elect, under section 453 of the Internal Revenue Code of 1954,…
2Cases cited15 opinions
- Lucas v. Pilliod Lumber Co.Supreme Court of the United States · 1930
- Pacific National Co. v. WelchSupreme Court of the United States · 1938
- Thrift v. CommissionerUnited States Tax Court · 1950
- S. Nicholas Jacobs and Dolores I. Jacobs v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- Cedar Valley Distillery, Inc. v. CommissionerUnited States Tax Court · 1951
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