Brodsky v. Commissioner
United States Tax Court
Held, amounts withheld as "dealer's reserve" by bank purchasing notes from petitioners, automobile dealers using an accrual method of accounting, which amounts are reflected on the bank's books to credit of petitioners, are income of petitioners in the year the notes are purchased.
1Opinion of the Court
OPINION.
LeMiee, Judge:
This proceeding involves deficiencies in income tax for the taxable years 1949 and 1950 in the amounts of $530.36 and $1,940.56, respectively.
The sole contested issue is whether the respondent erred in including in petitioners’ income for the years 1949 and 1950 certain amounts withheld by a bank out of sums due on the purchase of notes from petitioners, automobile dealers on an accrual basis, which were held as a dealer’s reserve and credited on the bank’s books to petitioners, pursuant to a written agreement.
All the facts have been stipulated and are found accordingly.…
2Cases cited1 opinion
- Blaine Johnson and His Wife, Evelyn K. Johnson v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1956
3Cited by19 opinions
- John R. Hansen and Shirley G. Hansen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Texas Trailercoach, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
- J. H. Schaeffer, Jr., and Opal R. Schaeffer v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1958
- Key Homes, Inc. v. CommissionerUnited States Tax Court · 1958
- Morgan v. CommissionerUnited States Tax Court · 1957
14 more not listed; retrieve them via the Exa API.