National Airlines, Inc. v. Commissioner
United States Tax Court
Prior to the fiscal year ended June 30, 1944, petitioner kept its books and reported its income for income tax purposes on a basis which reflected receipts from ticket sales whether or not the transportation represented by the tickets had been furnished. In January 1944 the Civil Aeronautics Board directed petitioner to keep its books in such a way as to defer receipts from tickets for which transportation had not actually been furnished.
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Prior to the fiscal year ended June 30, 1944, petitioner kept its books and reported its income for income tax purposes on a basis which reflected receipts from ticket sales whether or not the transportation represented by the tickets had been furnished. In January 1944 the Civil Aeronautics Board directed petitioner to keep its books in such a way as to defer receipts from tickets for which transportation had not actually been furnished. Petitioner requested permission from respondent to change its method of accounting for income tax purposes to the method prescribed by CAB. Respondent…
1Opinion of the Court
OPINION.
Hill, Judge--.
The question for decision is essentially whether respondent abused his discretion in refusing petitioner’s request to change its accounting method for tax purposes. Section 41 of the Internal Revenue Code1 vests respondent with discretion in prescribing or approving accounting methods for tax purposes) Prior to the . fiscal year ended June 30, 1944, petitioner had reported on a receipts basis in so far as ticket sales were concerned. After being directed by CAB to keep its books differently, petitioner requested respondent to permit it to report its income according to…
2Cases cited3 opinions
- Brown v. HelveringSupreme Court of the United States · 1934
- Your Health Club, Inc. v. CommissionerUnited States Tax Court · 1944
- South Tacoma Motor Co. v. CommissionerUnited States Tax Court · 1944
3Cited by35 opinions
- Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
- Beacon Publishing Company, a Kansas Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1955
- Patchen v. CommissionerUnited States Tax Court · 1956
- Automobile Club of New York, Inc. v. CommissionerUnited States Tax Court · 1959
- Josef C. Patchen and Aleyne E. Patchen v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
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