United Dressed Beef Co. v. Commissioner
United States Tax Court
A corporation engaged in slaughtering cattle and hogs and selling meat invoiced its products to customers at the ceiling prices fixed by the Government. The two owners of all the stock collected cash overceiling payments from customers, measured by the quantity of meat delivered. No record of these collections was maintained. Returns of the corporation prepared by accountants did not include these receipts.
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A corporation engaged in slaughtering cattle and hogs and selling meat invoiced its products to customers at the ceiling prices fixed by the Government. The two owners of all the stock collected cash overceiling payments from customers, measured by the quantity of meat delivered. No record of these collections was maintained. Returns of the corporation prepared by accountants did not include these receipts. The stockholders reported on their tax returns certain amounts as "commissions" or "miscellaneous income from other sources," but less than the amount of the overcollections determined by…
1Opinion of the Court
OPINION.
Tietjens, Judge:
The petitioners admit that Sam and Ben Borne, the sole stockholders of the corporation, received cash collections in excess of the ceiling price of meat sold by the corporation, as fixed by the Office of Price Administration. The amount of such collections is in issue. The respondent determined the deficiencies upon the basis that the collections amounted to $358,365.59, while the petitioners contend that they were not in excess of $129,000, the amount the individual petitioners reported on their returns. The second issue is whether the respondent erred in treating…
2Cases cited9 opinions
- Spies v. United StatesSupreme Court of the United States · 1943
- Commissioner v. WilcoxSupreme Court of the United States · 1946
- Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- Rogers v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1940
- United States v. Joliet & Chicago RailroadSupreme Court of the United States · 1942
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3Cited by43 opinions
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- Asphalt Industries, Inc. v. CommissionerUnited States Tax Court · 1966
- Weish Homes, Inc. v. CommissionerUnited States Tax Court · 1959
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