Legal Opinion

Wilson Furs, Inc. v. Commissioner

United States Board of Tax Appeals

Decided November 14, 1933No. Docket Nos. 57058, 57059Published

1. Where taxpayer, engaged in the retail business, sells garments on an installment payment plan, retaining the garments until paid for in full, and, upon failure of customers to make payment in full, cancels such sales and declares payments theretofore made forfeited, an amount set up on taxpayer's books of account in the taxable year in question as a reserve to meet possible claims for such forfeited deposits held, upon the evidence, not to be an allowable deduction in…

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1. Where taxpayer, engaged in the retail business, sells garments on an installment payment plan, retaining the garments until paid for in full, and, upon failure of customers to make payment in full, cancels such sales and declares payments theretofore made forfeited, an amount set up on taxpayer's books of account in the taxable year in question as a reserve to meet possible claims for such forfeited deposits held, upon the evidence, not to be an allowable deduction in computing net income for the taxable year. 2. Where the consolidated net loss of an affiliated group in 1926 represents the…

1Opinion of the Court

WILSON FURS, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

SELBERT, LTD., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Wilson Furs, Inc. v. Commissioner

Docket Nos. 57058, 57059.

United States Board of Tax Appeals

29 B.T.A. 319; 1933 BTA LEXIS 956;

November 14, 1933, Promulgated

1. Where taxpayer, engaged in the retail business, sells garments on an installment payment plan, retaining the garments until paid for in full, and, upon failure of customers to make payment in full, cancels such sales and declares payments theretofore made forfeited, an amount set up on…

2Cases cited12 opinions

  1. Woolford Realty Co. v. RoseSupreme Court of the United States · 1932
  2. United States v. Magnolia Petroleum Co.Supreme Court of the United States · 1928
  3. Delaware & Hudson Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  4. Ostheimer v. CommissionerUnited States Board of Tax Appeals · 1924
  5. Albert Leon & Son, Inc. v. CommissionerUnited States Board of Tax Appeals · 1933

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