Field Enterprises, Inc. v. United States

In this action, plaintiff seeks the refund of alleged over-payments of income tax for its fiscal years which ended September 30, 1955, and September 30, 1956, respectively. The total of the alleged overpayments (including interest) is $476,037.65.

Among plaintiff’s business activities were the publication and sale of the World Book Encyclopedia.1 Marketing was accomplished by plaintiff’s vast sales organization which *79relied upon personal solicitation. More than 80 percent of the purchases were made under the installment plan.

This case arises out of a dispute between plaintiff, an accrual-basis…