Automobile Club of New York, Inc. v. Commissioner
United States Tax Court
1. Petitioner's members paid their annual membership fees in advance. In reporting such fees petitioner, on an accrual basis, included in income only one-twelfth of each fee for each month of the year, thus leaving unreported for any given taxable year the portion of the fee allocable to the period of membership in the following taxable year, which, however, was reported in the following taxable year.
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1. Petitioner's members paid their annual membership fees in advance. In reporting such fees petitioner, on an accrual basis, included in income only one-twelfth of each fee for each month of the year, thus leaving unreported for any given taxable year the portion of the fee allocable to the period of membership in the following taxable year, which, however, was reported in the following taxable year. Held, the Commissioner properly required petitioner to report as income all the fees received during the taxable year. 2. Held, the Commissioner correctly required petitioner to report as income…
1Dissent
Pieeoe, /.,
dissenting: The Court’s opinion on the first issue of the instant case has brought to the forefront again two questions of major importance in the operation of our Federal income tax system, on which the positions taken by this Court appear to be out of harmony with the weight and trend of Courts of Appeals’ authority. These questions are:
1. Whether, under the accrual method of accounting, amounts received in one taxable year which are admittedly the price of services to be performed in future years, must as a matter of law be included in taxable income only in the year when…
2Cases cited20 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Lawrence v. CommissionerUnited States Tax Court · 1957
- Harrold v. Commissioner of Internal Revenue. Cromling v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1951
- Krim-Ko Corp. v. CommissionerUnited States Tax Court · 1951
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