Legal Opinion

General Gas Corp. v. Commissioner

United States Tax Court

Decided November 23, 1959No. Docket No. 63171PublishedCited by 20 opinions

Held: The fact that taxpayer transferred its customers' credit purchase notes to financing agencies without recourse does not require a different result from that reached in Commissioner v. Hansen, 360 U.S. 446. Nor is a different result called for by reason of the fact that the dealer's reserves included in part so-called finance or service charges.

1Opinion of the Court

OPINION.

Raum, Judge:

The Commissioner determined a deficiency in income tax in the amount of $379,848.55 for the calendar year 1952. The parties have filed a comprehensive stipulation of facts, and although some testimony was received, it does not appear to be necessary to make any findings beyond the stipulation which we hereby adopt as our findings of fact.

Petitioner, an accrual basis taxpayer, sold its products on installments, and arranged for financing by transferring its customers’ credit purchase notes to certain financing agencies without recourse. The financing agencies withheld a…

2Cases cited5 opinions

  1. Commissioner v. HansenSupreme Court of the United States · 1959
  2. Shoemaker-Nash, Inc. v. CommissionerUnited States Board of Tax Appeals · 1940
  3. Morgan v. CommissionerUnited States Tax Court · 1957
  4. Vance L. Wiley v. Commissioner of Internal Revenue, Frank D. Wiley v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1959
  5. Evans Motor Co. v. CommissionerUnited States Tax Court · 1957

3Cited by20 opinions

  1. American Can Co. v. CommissionerUnited States Tax Court · 1961
  2. Johnson v. CommissionerUnited States Tax Court · 1997
  3. Gunderson Bros. Engineering Corp. v. CommissionerUnited States Tax Court · 1964
  4. Western Oaks Bldg. Corp. v. CommissionerUnited States Tax Court · 1968
  5. Federated Dep't Stores, Inc. v. CommissionerUnited States Tax Court · 1968

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