Legal Opinion
Graff Chevrolet Company v. Ellis Campbell, Jr., District Director of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided March 29, 1965No. 21178_1PublishedCited by 71 opinions
1Opinion of the Court
WISDOM, Circuit Judge:
This case presents an apparent conflict between the adjustment provisions of section 481 of the Internal Revenue Code of 1954 and the statute of limitations, 1 section 6501(a) of the Code.
The taxpayer, Graff Chevrolet Company, is a retail automobile dealer in Grand Prairie, Texas. Graff sells automobiles under a deferred payment plan, discounting the purchasers’ promissory notes to a finance company. The finance company pays part of the discount price to the taxpayer and credits the rest to a “dealer reserve account” to secure the company against non-payment of the…
2Cases cited6 opinions
- Flora v. United StatesSupreme Court of the United States · 1960
- Commissioner v. HansenSupreme Court of the United States · 1959
- Offutt Housing Co. v. County of SarpySupreme Court of the United States · 1956
- Commissioner of Internal Revenue v. O. Liquidating CorporationCourt of Appeals for the Third Circuit · 1961
- Wright Contracting Company v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Wright Contracting CompanyCourt of Appeals for the Fifth Circuit · 1963
1 more not listed; retrieve them via the Exa API.
3Cited by71 opinions
- Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
- Knight-Ridder Newspapers, Inc. v. United StatesCourt of Appeals for the Eleventh Circuit · 1984
- Wayne Bolt & Nut Co. v. CommissionerUnited States Tax Court · 1989
- Schuster's Express, Inc. v. CommissionerUnited States Tax Court · 1976
- Dearborn Gage Co. v. CommissionerUnited States Tax Court · 1967
66 more not listed; retrieve them via the Exa API.