Frame v. Commissioner
United States Tax Court
Petitioner kept books for his sole proprietorship on an accrual basis. He made no change in such method or period of accounting, and did not request the Commissioner's permission to make any change. He filed his individual income tax returns on a cash basis.
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Petitioner kept books for his sole proprietorship on an accrual basis. He made no change in such method or period of accounting, and did not request the Commissioner's permission to make any change. He filed his individual income tax returns on a cash basis. Held: The Commissioner, in changing petitioner to the accrual basis for 1945, erred in adding to petitioner's income for 1945 the debit balance of accounts receivable shown on the books of account of the proprietorship at the beginning of the year. Commissioner v. Mnookin's Estate, 184 Fed. (2d) 89; Greene Motor Co., 5 T. C. 314. Z. W.…
1Opinion of the Court
OPINION.
Disney, Judge:
This case involves income tax for the calendar year 1945. Deficiency was determined in the amount of $44,215.22. Only a part thereof is involved here. The only question presented is whether the Commissioner erred in adding to petitioner’s net income $53,890.28 because of the addition to income of petitioner’s debit balance of accounts receivable on his books at the beginning of the taxable year. The problem is whether the Commissioner, in connection with requiring petitioner, who had made no change in his method of accounting, to change from the cash to the accrual…
2Cases cited8 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Greene Motor Co. v. CommissionerUnited States Tax Court · 1945
3 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
- Caldwell v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. CaldwellCourt of Appeals for the Second Circuit · 1953
- Fruehauf Trailer Co. v. CommissionerUnited States Tax Court · 1964
- Pursell v. CommissionerUnited States Tax Court · 1962
- Iley v. CommissionerUnited States Tax Court · 1952
- Commissioner of Internal Revenue v. SchuylerCourt of Appeals for the Second Circuit · 1952
28 more not listed; retrieve them via the Exa API.