Morgan v. Commissioner
United States Tax Court
Amounts retained by the purchaser of an automobile dealer's deferred payment contracts and credited to a reserve account on the books of the purchaser, held to be accruable income to the dealer in the year of sale of the contracts even though the amount of the reserve at the close of the year was not sufficient to allow the dealer to demand payment of any part thereof. Shoemaker-Nash, Inc., 41 B. T. A. 417, and Albert M. Brodsky, 27 T. C. 216, followed.
1Opinion of the Court
Atkins, Judge:
The respondent determined a deficiency in income tax for the calendar year 1950 in the amount of $1,076.40. The petitioner Dorothy O. Morgan is a party only by reason of having signed the joint income tax return for the year 1950.
The respondent made several adjustments to the reported income in determining the deficiency. The only issue is whether an automobile dealer partnership, of which the petitioner Arthur V. Morgan was a member, realized income through credits to a reserve account on the books of a bank to which the partnership assigned conditional sales contracts.
FINDINGS…
2Cases cited5 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Brodsky v. CommissionerUnited States Tax Court · 1956
- Johnson v. CommissionerUnited States Tax Court · 1955
- West Pontiac, Inc. v. CommissionerUnited States Tax Court · 1957
- Chester R. Shook, Administrator of the Estate of Alfred Russell, Deceased v. The United States of AmericaCourt of Appeals for the Sixth Circuit · 1956
3Cited by15 opinions
- John R. Hansen and Shirley G. Hansen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Gunderson Bros. Engineering Corp. v. CommissionerUnited States Tax Court · 1964
- Luhring Motor Co. v. CommissionerUnited States Tax Court · 1964
- Federated Dep't Stores, Inc. v. CommissionerUnited States Tax Court · 1968
- General Gas Corp. v. CommissionerUnited States Tax Court · 1959
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