National Bread Wrapping Machine Co. v. Commissioner
United States Tax Court
1. Accrual Method -- Reserves for Installation. -- Reserves for installation of machines sold by the petitioner which the petitioner was obligated to install for the purchasers, but which had not been installed at the end of the year, held, not deductible for the reason that installation services had not been performed.
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1. Accrual Method -- Reserves for Installation. -- Reserves for installation of machines sold by the petitioner which the petitioner was obligated to install for the purchasers, but which had not been installed at the end of the year, held, not deductible for the reason that installation services had not been performed. All that had accrued was the obligation to perform services. 2. Income from Patents. -- Income representing a portion of selling price of machines manufactured and sold by a foreign company under patent rights granted by the petitioner, held to be royalty income and not…
1Opinion of the Court
Atkins, Judge:
The respondent determined deficiencies in income tax for the calendar years 1949 and 1950 in the respective amounts o.f $1,065.47 and $1,297.70. The deficiencies determined result from the respondent’s disallowance of a deduction in each year of the amount of a reserve set up for installation of bread-wrapping machines which had been sold by the petitioner in the respective years under review, but which had not been installed at the end of the year. Such dis-allowance is assigned as error.
For the year 1950 the petitioner claims that it is entitled to a refund of income tax in…
2Cases cited23 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Waterman v. MacKenzieSupreme Court of the United States · 1891
- Brown v. HelveringSupreme Court of the United States · 1934
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
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3Cited by4 opinions
- VECO Corp. & Subsidiaries v. CommissionerUnited States Tax Court · 2013
- National Bread Wrapping Machine Co. v. CommissionerUnited States Tax Court · 1958
- Pyle v. CommissionerUnited States Tax Court · 1964
- Veco Corporation And Subsidiaries v. CommissionerUnited States Tax Court · 2013