Ireland v. Commissioner
United States Tax Court
Petitioners' original return for the year 1955 did not report on the installment basis the sale of a skating rink or disclose said sale in any manner, and the return did not include any payments received by the petitioners in 1955 from such sale. Held, the petitioners may not elect, under section 453 of the Internal Revenue Code of 1954, to report the sale on the installment basis in an amended return for 1955 filed by them in 1957.
1Opinion of the Court
MulRONEy, Judge:
The respondent determined a deficiency in the petitioners’ income tax for the year 1955 in the amount of $4,202.09. In an amendment to his answer the respondent claimed an increase in the income tax deficiency in the amount $19.44. Petitioners do not contest this increased portion of the deficiency. The issue is whether the petitioners made a timely election to report the gain from the sale of a roller skating rink in 1955 on the installment basis.
findings of fact.
Some of the facts have been stipulated and they are hereby incorporated by this reference.
W. A. Ireland and his…
2Cases cited14 opinions
- Lucas v. Pilliod Lumber Co.Supreme Court of the United States · 1930
- Pacific National Co. v. WelchSupreme Court of the United States · 1938
- Thrift v. CommissionerUnited States Tax Court · 1950
- S. Nicholas Jacobs and Dolores I. Jacobs v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- Cedar Valley Distillery, Inc. v. CommissionerUnited States Tax Court · 1951
9 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Reaver v. CommissionerUnited States Tax Court · 1964
- Farber v. CommissionerUnited States Tax Court · 1961
- Mamula v. CommissionerUnited States Tax Court · 1964
- Estate of Stamos v. CommissionerUnited States Tax Court · 1970
- C'De Baca v. CommissionerUnited States Tax Court · 1962
17 more not listed; retrieve them via the Exa API.