General Gas Corporation v. Commissioner of Internal Revenue

JOHN R. BROWN, Circuit Judge.

This appeal from the Tax Court involves two questions. The first is whether this accrual basis Taxpayer, a corporation, must include in its taxable income amounts held to its credit in a “Dealer’s Reserve Account” by a finance company which had purchased its customer notes during the year in which the finance company credits it to the dealer-Taxpayer. If that inquiry is answered affirmatively, the second issue must be resolved. Should the portions of the reserve which constitute finance charges imposed by the Taxpayer on its customers and included in the face of…