Legal Opinion

Vermont Transit Co. v. Commissioner

United States Tax Court

Decided March 10, 1953No. Docket No. 34152PublishedCited by 27 opinions

Petitioner paid into escrow a portion of the revenues which it earned from the operation of buses under certain franchises which it had purchased; that portion of the revenues, according to the purchase agreement, was to go to the seller. Held, such revenues were not excludible from petitioner's gross income.

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Petitioner paid into escrow a portion of the revenues which it earned from the operation of buses under certain franchises which it had purchased; that portion of the revenues, according to the purchase agreement, was to go to the seller. Held, such revenues were not excludible from petitioner's gross income. Held further, that the payment of such revenues into escrow on behalf of the seller was not deductible, since such payment represented merely part of the cost of acquiring the franchises.

1Opinion of the Court

OPINION.

Raum, Judge:

The respondent determined deficiencies in the income tax of the petitioner for the years 1942 and 1943 in the amounts of $11.19 and $178.92, respectively. Petitioner contested the deficiencies and claimed overpayments for each year. Certain issues raised by the petitioner have since been abandoned. The sole remaining issue is whether amounts of $54,262.18 and $37,347.78 were properly included in its gross income for 1942 and 1943, and, if so, whether corresponding deductions in the same amounts should be allowed.

The facts have been stipulated and are so found. The…

2Cases cited8 opinions

  1. Lucas v. EarlSupreme Court of the United States · 1930
  2. Palmer v. BenderSupreme Court of the United States · 1932
  3. Anderson v. HelveringSupreme Court of the United States · 1940
  4. Thomas v. PerkinsSupreme Court of the United States · 1937
  5. Helvering v. Elbe Oil Land Development Co.Supreme Court of the United States · 1938

3 more not listed; retrieve them via the Exa API.

3Cited by27 opinions

  1. Dustin v. CommissionerUnited States Tax Court · 1969
  2. Radio Station WBIR, Inc. v. CommissionerUnited States Tax Court · 1959
  3. Olin Bryant and Vanell Bryant v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
  4. Bryant v. CommissionerUnited States Tax Court · 1966
  5. Hollywood Baseball Ass'n v. CommissionerUnited States Tax Court · 1964

22 more not listed; retrieve them via the Exa API.

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