Legal Opinion

General Gas Corp. v. Commissioner

United States Tax Court

Decided November 23, 1959No. Docket No. 63171Published

Held: The fact that taxpayer transferred its customers' credit purchase notes to financing agencies without recourse does not require a different result from that reached in Commissioner v. Hansen, 360 U.S. 446. Nor is a different result called for by reason of the fact that the dealer's reserves included in part so-called finance or service charges.

1Opinion of the Court

General Gas Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

General Gas Corp. v. Commissioner

Docket No. 63171

United States Tax Court

33 T.C. 303; 1959 U.S. Tax Ct. LEXIS 37;

November 23, 1959, Filed

Decision will be entered for the respondent.

Held: The fact that taxpayer transferred its customers' credit purchase notes to financing agencies without recourse does not require a different result from that reached in Commissioner v. Hansen, 360 U.S. 446. Nor is a different result called for by reason of the fact that the dealer's reserves included in part so-called finance or…

2Cases cited7 opinions

  1. Commissioner v. HansenSupreme Court of the United States · 1959
  2. Shoemaker-Nash, Inc. v. CommissionerUnited States Board of Tax Appeals · 1940
  3. General Gas Corp. v. CommissionerUnited States Tax Court · 1959
  4. Morgan v. CommissionerUnited States Tax Court · 1957
  5. Vance L. Wiley v. Commissioner of Internal Revenue, Frank D. Wiley v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1959

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