Smith v. Davis

Petitioners are partners engaged in the contracting and construction business. They claim that on January 1, 1942, the United States owed them a balance of $29,831.10. This amount was due under the terms of two contracts for work, labor and materials furnished in connection with the construction of two airports for the use of the United States Army. Petitioners state that this balance “was in the nature of an open account and represented an account receivable” in their hands.

The respondent tax officials of Fulton County, Georgia, sought to assess this open account for state and county ad…