Legal Opinion

Sullivan v. Commissioner

United States Tax Court

Decided September 27, 1963No. Docket No. 91719Unpublished

1. Held, adjustments with respect to principal petitioner's proprietorship's opening inventory, and accounts receivable and payable, made by respondent acting pursuant to section 481, I.R.C. 1954, to prevent duplications and omissions, following petitioner's voluntary change in 1954 from the cash to a modified accrual method of accounting for and reporting proprietorship income, were proper. 2. Held, petitioner is not entitled to a bad debt deduction for an account…

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1. Held, adjustments with respect to principal petitioner's proprietorship's opening inventory, and accounts receivable and payable, made by respondent acting pursuant to section 481, I.R.C. 1954, to prevent duplications and omissions, following petitioner's voluntary change in 1954 from the cash to a modified accrual method of accounting for and reporting proprietorship income, were proper. 2. Held, petitioner is not entitled to a bad debt deduction for an account receivable (which arose at the time petitioner's proprietorship was on the cash basis), the amount of which had never been…

1Opinion of the Court

Cornelius J. Sullivan and Lillian Sullivan v. Commissioner.

Sullivan v. Commissioner

Docket No. 91719.

United States Tax Court

T.C. Memo 1963-264; 1963 Tax Ct. Memo LEXIS 77; 22 T.C.M. (CCH) 1331; T.C.M. (RIA) 63264;

September 27, 1963

1. Held, adjustments with respect to principal petitioner's proprietorship's opening inventory, and accounts receivable and payable, made by respondent acting pursuant to section 481, I.R.C. 1954, to prevent duplications and omissions, following petitioner's voluntary change in 1954 from the cash to a modified accrual method of accounting for and reporting…

2Cases cited10 opinions

  1. Commissioner v. AckerSupreme Court of the United States · 1959
  2. Elliott v. CommissionerUnited States Tax Court · 1963
  3. Smith v. CommissionerUnited States Tax Court · 1953
  4. Pursell v. CommissionerUnited States Tax Court · 1962
  5. F.B. Blansett and Ethel Blansett v. United StatesCourt of Appeals for the Eighth Circuit · 1960

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