Koebig & Koebig, Inc. v. Commissioner
United States Tax Court
In 1951, respondent made a ruling that because of the nature of petitioner's business, petitioner could not use any long-term contract method of accounting and computing taxable income.
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In 1951, respondent made a ruling that because of the nature of petitioner's business, petitioner could not use any long-term contract method of accounting and computing taxable income. In 1953, petitioner adopted an accrual method of accounting and computing taxable income and it consistently prepared under the same method its returns for each of the years 1953 through 1961. Respondent did not question any of these returns up to the 1959 return, or the right of petitioner to use such accrual method although it was apparent from each return beginning in 1953 that a billings method under which…
1Opinion of the Court
Koebig & Koebig, Inc. v. Commissioner.
Koebig & Koebig, Inc. v. Commissioner
Docket No. 719-62.
United States Tax Court
T.C. Memo 1964-32; 1964 Tax Ct. Memo LEXIS 302; 23 T.C.M. (CCH) 170; T.C.M. (RIA) 64032;
February 12, 1964
In 1951, respondent made a ruling that because of the nature of petitioner's business, petitioner could not use any long-term contract method of accounting and computing taxable income. In 1953, petitioner adopted an accrual method of accounting and computing taxable income and it consistently prepared under the same method its returns for each of the years 1953 through 1961.…
2Cases cited9 opinions
- Brown v. HelveringSupreme Court of the United States · 1934
- Patchen v. CommissionerUnited States Tax Court · 1956
- Josef C. Patchen and Aleyne E. Patchen v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
- Sam W. Emerson Co. v. CommissionerUnited States Tax Court · 1962
- Wright Contracting Co. v. CommissionerUnited States Tax Court · 1961
4 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
- Auburn Packing Co. v. CommissionerUnited States Tax Court · 1973
- Hamilton Industries, Inc. v. CommissionerUnited States Tax Court · 1991
- Commissioner of Internal Revenue v. Joseph E. Seagram & Sons, Inc.Court of Appeals for the Second Circuit · 1968
- Auburn Packing Co. v. CommissionerUnited States Tax Court · 1973
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