Dell v. Commissioner
United States Tax Court
P is the sole shareholder of D & D, an S corporation that operated both a wholesale petroleum business and retail gasoline filling stations.
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P is the sole shareholder of D & D, an S corporation that operated both a wholesale petroleum business and retail gasoline filling stations. For internal accounting purposes it designated its retail operations as "D & D 2", and on its books treated transfers of inventory to its filling stations as "sales" to "D & D 2", accompanied by corresponding "accounts receivable" in favor of D & D. When this practice was discontinued, there remained on D & D's books a balance in the "accounts receivable" account attributable to such "sales". D & D claimed bad debt deductions in respect of the net amount…
1Opinion of the Court
ROBERT DELL AND NANCY L. DELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Dell v. Commissioner
Docket No. 3783-93
United States Tax Court
T.C. Memo 1995-315; 1995 Tax Ct. Memo LEXIS 317; 70 T.C.M. (CCH) 69;
July 18, 1995, Filed
Decision will be entered under Rule 155.
P is the sole shareholder of D & D, an S corporation that operated both a wholesale petroleum business and retail gasoline filling stations. For internal accounting purposes it designated its retail operations as "D & D 2", and on its books treated transfers of inventory to its filling stations as "sales" to "D & D 2",…
2Cases cited5 opinions
- W. L. Moody Cotton Co. v. CommissionerCourt of Appeals for the Fifth Circuit · 1944
- W. L. Moody Cotton Co. v. CommissionerUnited States Tax Court · 1943
- J. E. Mergott Co. v. CommissionerCourt of Appeals for the Third Circuit · 1949
- H. A. Carey Co. v. CommissionerUnited States Tax Court · 1957
- Sidney Ross Co. v. CommissionerUnited States Board of Tax Appeals · 1932