Record Wide Distributors, Inc. v. Commissioner of Internal Revenue

HENLEY, Senior Circuit Judge.

Taxpayer Record Wide Distributors, Inc. appeals the decision of the tax court upholding the Commissioner’s assessment of certain deficiencies for the tax years 1972, 1973 and 1974. We affirm.

Taxpayer, a Missouri corporation, is a wholesale distributor of records and tapes, and deals primarily in “cut-outs,” budget merchandise that the manufacturer is unable to sell at market price. Because cutouts have limited marketability, taxpayer’s normal business practice is to send an invoice with each shipment to its customers, but to defer immediate payment in order to…