Morris-Poston Coal Co. v. Commissioner of Int. Rev.

DENISON, Circuit Judge.

For many years prior to 1921, the petitioner had been in the business of buying and selling coal. It regularly kept its books upon a system which, in its income tax reports, it described as the cash receipts and disbursement system. The accounting year-ended December 31. All expenses of operation outstanding at that date were assembled and paid within the next few days and written up as of December 31. Invoices for coal sold (the sole receipts excepting interest) were commonly paid early in January and entered on the December receipts. The pay rolls owing to the miners…