Decision, Inc. v. Commissioner
United States Tax Court
Held: 1. Petitioner, an accrual basis taxpayer, may not defer the recognition of income, with respect to revenue received for advertising in certain of its publications, from the year the revenue is received to the year the publication is printed and distributed. 2. Petitioner is not required to recognize income at the time it receives its orders from customers without receiving payment, even though the orders are noncancelable.
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Held: 1. Petitioner, an accrual basis taxpayer, may not defer the recognition of income, with respect to revenue received for advertising in certain of its publications, from the year the revenue is received to the year the publication is printed and distributed. 2. Petitioner is not required to recognize income at the time it receives its orders from customers without receiving payment, even though the orders are noncancelable. Income is to be recognized only when payment is due from the customer or when it is actually received, whichever is earlier. Orders received in 1963 which were not…
1Opinion of the Court
Hoyt, Judge:
Respondent determined deficiencies in income tax and additions to the tax1 as follows:
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An overassessment in the amount of $2,539 was determined for 1963.
Petitioner has conceded the correctness of certain of respondent’s adjustments involving depreciation, repair expense, and charitable contribution deductions. Thus, the issues remaining for decision are (1) whether petitioner must recognize income in the period in which it receives purchase orders, the period in which it bills its customers, or the period in which it prints its publications and fills its orders, and…
2Cases cited7 opinions
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- Schulde v. CommissionerSupreme Court of the United States · 1963
- Interstate Commerce Commission v. Central Vermont Railway, Inc.Supreme Court of the United States · 1961
- Cox v. CommissionerUnited States Tax Court · 1965
- Charles F. Dally and Sarafrancis Dally v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
2 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Hallmark Cards, Inc. v. CommissionerUnited States Tax Court · 1988
- Artnell Co. v. CommissionerUnited States Tax Court · 1967
- New England Tank Industries, Inc. v. CommissionerUnited States Tax Court · 1968
- Orange & Rockland Utilities, Inc. v. CommissionerUnited States Tax Court · 1986
- Public Service Co. v. CommissionerUnited States Tax Court · 1982
18 more not listed; retrieve them via the Exa API.