Legal Opinion

Decision, Inc. v. Commissioner

United States Tax Court

Decided October 18, 1966No. Docket Nos. 3905-64, 5379-64Published

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

Decision, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Decision, Inc. v. Commissioner

Docket Nos. 3905-64, 5379-64

United States Tax Court

47 T.C. 58; 1966 U.S. Tax Ct. LEXIS 29;

October 18, 1966, Filed

Decisions will be entered under Rule 50.

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…

2Cases cited8 opinions

  1. American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
  2. Schulde v. CommissionerSupreme Court of the United States · 1963
  3. Interstate Commerce Commission v. Central Vermont Railway, Inc.Supreme Court of the United States · 1961
  4. Cox v. CommissionerUnited States Tax Court · 1965
  5. Charles F. Dally and Sarafrancis Dally v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955

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