Vermont Transit Co. v. Commissioner
United States Tax Court
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
- Lucas v. EarlSupreme Court of the United States · 1930
- Palmer v. BenderSupreme Court of the United States · 1932
- Anderson v. HelveringSupreme Court of the United States · 1940
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- Helvering v. Elbe Oil Land Development Co.Supreme Court of the United States · 1938
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