Legal Opinion

Markson Bros. v. Commissioner

United States Tax Court

Decided December 12, 1950No. Docket Nos. 11942, 14302Published

Petitioner, on a calendar year basis, was engaged in installment selling and at all times computed ordinary income under section 44 (a) of the Internal Revenue Code.

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Petitioner, on a calendar year basis, was engaged in installment selling and at all times computed ordinary income under section 44 (a) of the Internal Revenue Code. It elected under section 736 (a), for the purposes of the excess profits tax, to compute income on the accrual basis in lieu of the basis provided by section 44 (a), and on that basis included in its taxable excess profits income gross profits included in uncollected installment accounts receivable (from installment sales made after January 1, 1940). Held, that such gross profits were properly included in "accumulated earnings…

1Opinion of the Court

Markson Bros., Petitioner, v. Commissioner of Internal Revenue, Respondent

Markson Bros. v. Commissioner

Docket Nos. 11942, 14302

United States Tax Court

15 T.C. 839; 1950 U.S. Tax Ct. LEXIS 26;

December 12, 1950, Promulgated

Decisions will be entered under Rule 50.

Petitioner, on a calendar year basis, was engaged in installment selling and at all times computed ordinary income under section 44 (a) of the Internal Revenue Code. It elected under section 736 (a), for the purposes of the excess profits tax, to compute income on the accrual basis in lieu of the basis provided by section 44 (a), and on…

Also in this document: Concurrence.

2Cases cited5 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. J. L. Goodman Furniture Co. v. CommissionerUnited States Tax Court · 1948
  3. Kimbrell's Home Furnishings, Inc. v. CommissionerUnited States Tax Court · 1946
  4. Hart Furniture Co. v. CommissionerUnited States Tax Court · 1949
  5. Markson Bros. v. CommissionerUnited States Tax Court · 1950

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