Cal-Maine Foods, Inc. v. Commissioner
United States Tax Court
"Farms" and "Dairy Fresh," wholly owned subsidiaries of P, are farming corporations. Before and for the year in issue, "Farms" and "Dairy Fresh" used the cash receipts and disbursements method of accounting for tax purposes.
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"Farms" and "Dairy Fresh," wholly owned subsidiaries of P, are farming corporations. Before and for the year in issue, "Farms" and "Dairy Fresh" used the cash receipts and disbursements method of accounting for tax purposes. Pursuant to sec. 447(a) of the Internal Revenue Code of 1954, effective for the first taxable year beginning after Dec. 31, 1976, "Farms" and "Dairy Fresh" were required to change to the accrual method of accounting unless one of the specific exceptions to sec. 447(a) applied. In order to satisfy the "family corporation" exception to sec. 447(a), P arranged, through…
1Opinion of the Court
HAMBLEN, Judge:
Respondent determined a deficiency in petitioner’s Federal income tax for the fiscal year ended June 3, 1978, in the amount of $1,221,784.
After concessions by the parties, the issue for decision is whether for the fiscal year ended June 3, 1978, petitioner is entitled to use the cash receipts and disbursements method of accounting for its farm income from two of its subsidiary corporations, or whether that income must be reported on the accrual method of accounting pursuant to section 447(a).1
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly. The…
2Cases cited47 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Corliss v. BowersSupreme Court of the United States · 1930
- Aaron v. Securities & Exchange CommissionSupreme Court of the United States · 1980
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
42 more not listed; retrieve them via the Exa API.
3Cited by76 opinions
- Washington v. Comm'rUnited States Tax Court · 2003
- Alumax Inc. v. CommissionerUnited States Tax Court · 1997
- Phillips Petroleum Co. v. CommissionerUnited States Tax Court · 1991
- Gerdau MacSteel, Inc. & Affiliated Subsidiaries v. CommissionerUnited States Tax Court · 2012
- Holman v. Comm'rUnited States Tax Court · 2008
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