Legal Opinion

Palm Beach Mather Co. v. Commissioner

United States Board of Tax Appeals

Decided October 29, 1931No. Docket No. 43850PublishedCited by 2 opinions

1. Upon change from the accrual to installment basis of accounting, double taxation does not result from the inclusion in gross income of amounts actually received in a taxable year on account of installment sales made and reported on an accrual basis of accounting as income in previous years. 2. Upon change from the accrual to installment basis of accounting, collections in a taxable year on account of accounts receivable representing sales in prior years are income in the…

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1. Upon change from the accrual to installment basis of accounting, double taxation does not result from the inclusion in gross income of amounts actually received in a taxable year on account of installment sales made and reported on an accrual basis of accounting as income in previous years. 2. Upon change from the accrual to installment basis of accounting, collections in a taxable year on account of accounts receivable representing sales in prior years are income in the taxable year and not a return of capital. 3. Upon change from the accrual to installment basis, mere bookkeeping entries…

1Opinion of the Court

*538OPINION.

McMahon:

Petitioner alleges three errors and these will be disposed of in the order stated.

1. With respect to the first assignment of error, relating to the addition to nét income for the taxable period of $13,887.86, representing collections received during taxable period on sales made prior thereto, petitioner contends that, having changed its method of reporting taxable income from the accrual to the installment basis, collections in the taxable period on account of sales made in prior periods should be excluded from gross income of the taxable period for the reasons (a) that…

2Cases cited2 opinions

  1. United States v. MitchellSupreme Court of the United States · 1926
  2. United States v. Supplee-Biddle Hardware Co.Supreme Court of the United States · 1924

3Cited by2 opinions

  1. Chemung Canal Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  2. Palm Beach Mather Co. v. CommissionerUnited States Board of Tax Appeals · 1931

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