Cox v. Commissioner
United States Tax Court
T, an accrual basis corporation, performs investment management services for clients who pay quarterly fees measured from the date such services were first engaged by the particular client and based upon the appraised value of the client's account as of the beginning of each quarter.
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T, an accrual basis corporation, performs investment management services for clients who pay quarterly fees measured from the date such services were first engaged by the particular client and based upon the appraised value of the client's account as of the beginning of each quarter. Held: (1) T may not "defer" as income those portions of the fees for the quarter extending beyond the close of T's taxable year where such fees have in fact been received or were otherwise properly accruable by T during that year. Schlude v. Commissioner, 372 U.S. 128. Fees properly accruable determined.(2) Fees…
1Opinion of the Court
The Commissioner determined the following deficiencies in income taxes for the year 1960:
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The cases were consolidated for trial.
Petitioners are the stockholders of Dodge & Cox, Inc., which elected to be taxed under subchapter S of the Internal Revenue Code of 1954 as amended. The issues presented herein for decision all concern the income of the corporation. They are as follows:(1) Whether an accrual basis taxpayer which contracts to furnish investment management services during a period extending beyond the close of the taxable year is required to accrue and report as gross…
2Cases cited9 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Commissioner v. HansenSupreme Court of the United States · 1959
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- Schulde v. CommissionerSupreme Court of the United States · 1963
- Continental Tie & Lumber Co. v. United StatesSupreme Court of the United States · 1932
4 more not listed; retrieve them via the Exa API.
3Cited by46 opinions
- BJR Corp. v. CommissionerUnited States Tax Court · 1976
- Dearborn Gage Co. v. CommissionerUnited States Tax Court · 1967
- Hallmark Cards, Inc. v. CommissionerUnited States Tax Court · 1988
- Farrara v. CommissionerUnited States Tax Court · 1965
- Bay State Gas Co. v. CommissionerUnited States Tax Court · 1980
41 more not listed; retrieve them via the Exa API.