Legal Opinion

Collegiate Cap & Gown Co. v. Commissioner

United States Tax Court

Decided June 19, 1978No. Docket No. 4018-69Unpublished

Petitioner, Collegiate Cap and Gown Company, was transferee of Cap and Gown Company. Under petitioner's accounting method it deferred reporting prepaid income until the taxable year the services which related to that prepaid income were performed which was the taxable year following the taxable year of receipt.

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Petitioner, Collegiate Cap and Gown Company, was transferee of Cap and Gown Company. Under petitioner's accounting method it deferred reporting prepaid income until the taxable year the services which related to that prepaid income were performed which was the taxable year following the taxable year of receipt. Cap and Gown consistently reported its income in this manner since at least 1954. Held, the result in this case is controlled by the case of Artnell Co. v. Commissioner,400 F. 2d 981 (7th Cir. 1968), revg. and remanding 48 T.C. 411 (1967), supp. opinion T.C. Memo. 1970-85, under our…

1Opinion of the Court

COLLEGIATE CAP AND GOWN COMPANY, Transferee, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Collegiate Cap & Gown Co. v. Commissioner

Docket No. 4018-69.

United States Tax Court

T.C. Memo 1978-226; 1978 Tax Ct. Memo LEXIS 290; 37 T.C.M. (CCH) 960; T.C.M. (RIA) 78226;

June 19, 1978, Filed

Petitioner, Collegiate Cap and Gown Company, was transferee of Cap and Gown Company. Under petitioner's accounting method it deferred reporting prepaid income until the taxable year the services which related to that prepaid income were performed which was the taxable year following the taxable year of…

2Cases cited11 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  3. American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
  4. Schulde v. CommissionerSupreme Court of the United States · 1963
  5. Artnell Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1968

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