Triboro Coach Corp. v. Commissioner
United States Tax Court
Triboro, an accrual basis taxpayer, operated suburban bus lines in Queens County, New York. In the fiscal years 1949 to 1952 passengers might transfer between City-owned transit lines and suburban bus lines by paying a combination ride fare. In 1949 and 1950 Triboro was allowed one-half cent per rider for the accounting for combination rides. Triboro asked for 1.5 cents for such accounting. In 1949 City representatives offered 1 cent which Triboro refused.
Read the full summary
Triboro, an accrual basis taxpayer, operated suburban bus lines in Queens County, New York. In the fiscal years 1949 to 1952 passengers might transfer between City-owned transit lines and suburban bus lines by paying a combination ride fare. In 1949 and 1950 Triboro was allowed one-half cent per rider for the accounting for combination rides. Triboro asked for 1.5 cents for such accounting. In 1949 City representatives offered 1 cent which Triboro refused. In 1951 Triboro accepted the City's offer. In the division of the combination fares for the year 1952 Triboro was allowed 1 cent per ride…
1Opinion of the Court
Teetjens, Judge:
The respondent determined a deficiency in income and excess profits tax of $76,652.78 for the fiscal year ended June 30, 1952, and a 5 per cent addition to the tax for late filing, amounting to $3,832.64. The principal issue is whether an amount credited to the petitioner in the taxable year is includible in gross income for that year or was aecruable in earlier years. By amendment to the petition there is raised the alternative contention that if the amount is, for income tax purposes, includible in gross income in the taxable year it is abnormal income within the provisions…
2Cases cited12 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Continental Tie & Lumber Co. v. United StatesSupreme Court of the United States · 1932
7 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Continental Can Company, Inc. v. The United StatesUnited States Court of Claims · 1970
- Bell Aircraft Corp. v. CommissionerUnited States Tax Court · 1959
- Beauty Acquisition Corp. v. CommissionerUnited States Tax Court · 1995
- Bell Aircraft Corp. v. CommissionerUnited States Tax Court · 1959
- Continental Can Company, Inc. v. The United StatesUnited States Court of Claims · 1970
2 more not listed; retrieve them via the Exa API.