Legal Opinion

Luhring Motor Co. v. Commissioner

United States Tax Court

Decided July 17, 1964No. Docket No. 80278Published

1. Petitioner, an accrual basis taxpayer, sold automobiles during the taxable year 1955 on a deferred payment basis. The purchaser executed a conditional sale contract, which set forth the "total time price" of the car, including, inter alia, finance charges. The total amount of finance charges (which consisted of interest and collection fees) for the term of the contract was set forth separately therein.

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1. Petitioner, an accrual basis taxpayer, sold automobiles during the taxable year 1955 on a deferred payment basis. The purchaser executed a conditional sale contract, which set forth the "total time price" of the car, including, inter alia, finance charges. The total amount of finance charges (which consisted of interest and collection fees) for the term of the contract was set forth separately therein. The total finance charge was divided by the number of monthly payments provided in the contract and payable at fixed dates over the term of the contract to determine the monthly finance…

1Opinion of the Court

Luhring Motor Company, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Luhring Motor Co. v. Commissioner

Docket No. 80278

United States Tax Court

42 T.C. 732; 1964 U.S. Tax Ct. LEXIS 74;

July 17, 1964, Filed

Decision will be entered under Rule 50.

1. Petitioner, an accrual basis taxpayer, sold automobiles during the taxable year 1955 on a deferred payment basis. The purchaser executed a conditional sale contract, which set forth the "total time price" of the car, including, inter alia, finance charges. The total amount of finance charges (which consisted of interest and collection…

2Cases cited36 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
  3. Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
  4. Commissioner v. HansenSupreme Court of the United States · 1959
  5. Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960

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