Cuba R. Co. v. Commissioner
United States Tax Court
Income -- Accrual. -- A taxpayer using an accrual method of accounting does not have to accrue an item where it appears at the end of the taxable year that there is real doubt as to the collectibility of the item.
1Opinion of the Court
OPINION.
Murdock, Judge:
The principles applicable in a case like this are sufficiently set forth in the following quotation from San Francisco Stevedoring Co., 8 T. C. 222:
*. * * A taxpayer, using an accrual method of accounting, must accrue an item in the year in which the taxpayer acquires a fixed and unconditional right to receive the amount, even.though actual payment is to be deferred. There must he no contingency or unreasonable uncertainty qualifying the payment or receipt. Income does not accrue to a taxpayer using an accrual method until there arises in him a fixed or unconditional…
2Cases cited7 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Continental Tie & Lumber Co. v. United StatesSupreme Court of the United States · 1932
- United States v. Safety Car Heating & Lighting Co.Supreme Court of the United States · 1936
- Estate of Putnam v. CommissionerSupreme Court of the United States · 1945
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Cuba R. Co. v. CommissionerUnited States Tax Court · 1947