Legal Opinion

Evans Motor Co. v. Commissioner

United States Tax Court

Decided December 30, 1957No. Docket No. 66001Published

Petitioner is an automobile dealer and sells automobiles with downpayment of cash or trade-in payment with balance of purchase price being payable in monthly installments provided for in conditional sales contracts. Petitioner sold some of these contracts to a finance company which remitted part of the sales price in cash and credited part to petitioner in a "Special Reserve" account.

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Petitioner is an automobile dealer and sells automobiles with downpayment of cash or trade-in payment with balance of purchase price being payable in monthly installments provided for in conditional sales contracts. Petitioner sold some of these contracts to a finance company which remitted part of the sales price in cash and credited part to petitioner in a "Special Reserve" account. It was provided in the contract that amounts accumulated to petitioner in the special reserve account were to be held by the finance company until such time as those amounts equal or exceed 3 per cent of "our…

1Opinion of the Court

Evans Motor Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Evans Motor Co. v. Commissioner

Docket No. 66001

United States Tax Court

29 T.C. 555; 1957 U.S. Tax Ct. LEXIS 5;

December 30, 1957, Filed

Decision will be entered for the respondent.

Petitioner is an automobile dealer and sells automobiles with downpayment of cash or trade-in payment with balance of purchase price being payable in monthly installments provided for in conditional sales contracts. Petitioner sold some of these contracts to a finance company which remitted part of the sales price in cash and credited part…

2Cases cited3 opinions

  1. Blaine Johnson and His Wife, Evelyn K. Johnson v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1956
  2. Keasbey & Mattison Co. v. United StatesCourt of Appeals for the Third Circuit · 1944
  3. Evans Motor Co. v. CommissionerUnited States Tax Court · 1957

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