Rhombar Co. v. Commissioner
United States Tax Court
1. Held, that the amounts of certain installment obligations payable to the petitioner, but unpaid, in the taxable year ended Jan. 31, 1959, did not constitute omitted items of gross income; that therefore the 6-year statute of limitations provided by sec. 6501(e)(1)(A) of the Internal Revenue Code of 1954 is not applicable; and that assessment of any deficiency for such year is barred. 2. Held, further, that portions of installment payments received by the petitioner in the…
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1. Held, that the amounts of certain installment obligations payable to the petitioner, but unpaid, in the taxable year ended Jan. 31, 1959, did not constitute omitted items of gross income; that therefore the 6-year statute of limitations provided by sec. 6501(e)(1)(A) of the Internal Revenue Code of 1954 is not applicable; and that assessment of any deficiency for such year is barred. 2. Held, further, that portions of installment payments received by the petitioner in the taxable years ended Jan. 31, 1960, 1961, and 1962, constituted selling price of property used in its trade or business…
1Opinion of the Court
Atkins, Judge:
The respondent determined deficiences in income tax (including the accumulated earnings tax) for the taxable years ended January 31,1959,1960,1961, and 1962, in the respective amounts of $55,333.09, $37,336.78, $19,803.51, and $24,227.41.
The issues raised by the pleadings are: (1) Whether assessment of any deficiency for the taxable year 1959 is barred by the statute of limitations; (2) whether the amounts of installment obligations which were payable, but unpaid, in the taxable years 1959 and 1960 constituted taxable income to the petitioner in those years; (3) whether any…
2Cases cited8 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Helvering v. GowranSupreme Court of the United States · 1937
- Reis v. CommissionerUnited States Tax Court · 1942
- Reis v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1944
- Edward F. Webber v. Commissioner or Internal Revenue, Edward F. Webber and Lelia Vesta Webber v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1955
3 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Burbage v. CommissionerUnited States Tax Court · 1984
- Rhombar Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Harlan v. Comm'rUnited States Tax Court · 2001
- Powder Mill Realty Trust v. CommissionerUnited States Tax Court · 1973
- Leavens v. CommissionerCourt of Appeals for the Third Circuit · 1972
11 more not listed; retrieve them via the Exa API.