Harbor Plywood Corp. v. Commissioner
United States Tax Court
Petitioner was a member stockholder of a cooperative nonprofit association organized as a corporation under the laws of the State of Washington (Rem. Rev. Stat., §§ 3904-3923) to engage in the export of plywood and other forest products as authorized by the Webb Export Trade Act.
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Petitioner was a member stockholder of a cooperative nonprofit association organized as a corporation under the laws of the State of Washington (Rem. Rev. Stat., §§ 3904-3923) to engage in the export of plywood and other forest products as authorized by the Webb Export Trade Act. During each of the taxable years 1943, 1944, and 1945 the association, pursuant to its bylaws, issued to petitioner a credit memorandum, representing petitioner's pro rata share of the excess of the association's income over its expenses for the year, and credited such amounts to petitioner in its books. In each…
1Opinion of the Court
OPINION.
LeMiee, Judge-.
Our sole question here is whether the amounts represented by the credit memorandums issued by Pacific are taxable to petitioner in the years when it received them, as contended by the respondent, or in the years when they were paid by Pacific, as petitioner contends; or, as both parties contend in the alternative, in the years .when renegotiation of Pacific, became barred by the statute of limitations.
A taxpayer keeping its books and making its returns on an accrual basis must report income when the right to receive it becomes fixed. Spring City Foundry Co. v.…
2Cases cited5 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- United States v. Safety Car Heating & Lighting Co.Supreme Court of the United States · 1936
- Petit v. CommissionerUnited States Tax Court · 1947
- Veit v. CommissionerUnited States Tax Court · 1947
3Cited by37 opinions
- Long Poultry Farms, Incorporated v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
- Puget Sound Plywood, Inc. v. CommissionerUnited States Tax Court · 1965
- Carpenter v. CommissionerUnited States Tax Court · 1953
- Colony Farms Cooperative Dairy, Inc. v. CommissionerUnited States Tax Court · 1951
- Caswell v. CommissionerUnited States Tax Court · 1952
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