West Pontiac, Inc. v. Commissioner
United States Tax Court
Held, the amount representing the increase in an accrual basis automobile dealer's reserve account with a finance company from March 10, 1950, to December 31, 1950, pursuant to an agreement whereby the dealer discounted its deferred payment automobile contracts to the finance company, is taxable income to the dealer in 1950.
1Opinion of the Court
OPINION.
BRUce, Judge:
Respondent determined deficiencies in petitioner’s income tax for the years 1949 and 1950 as follows:
Year Deficiency
1949_ $1,654.62
1950_ 4,404. 06
Petitioner concedes its liability for the full amount of the deficiency for the taxable year 1949. The sole issue is whether respondent correctly included in petitioner’s income for the year 1950 an amount representing the increase in petitioner’s dealer’s reserve with a finance company from March 10,1950, until December 31,1950.
All of the facts were stipulated and are so found and incorporated herein by this reference.
Petitioner…
2Cases cited5 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Brown v. HelveringSupreme Court of the United States · 1934
- Patchen v. CommissionerUnited States Tax Court · 1956
- Blaine Johnson and His Wife, Evelyn K. Johnson v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1956
- Brodsky v. CommissionerUnited States Tax Court · 1956
3Cited by10 opinions
- John R. Hansen and Shirley G. Hansen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Texas Trailercoach, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
- Morgan v. CommissionerUnited States Tax Court · 1957
- Kilborn v. CommissionerUnited States Tax Court · 1957
- West Pontiac, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
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