Smith v. Commissioner
United States Tax Court
In 1974 and 1975, P was a dealer in used cars, and many of the sales were made on credit. P held the notes and reported the payments thereon as income when he received them. Held, P must report the income from the sale of cars by the accrual method and must report the face amount of the notes as income when received. Held, further, P is entitled to deductions for reasonable additions to a reserve for bad debts. Sec. 166, I.R.C. 1954.
1Opinion of the Court
LYNN L. SMITH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Smith v. Commissioner
Docket No. 1449-79.
United States Tax Court
T.C. Memo 1983-472; 1983 Tax Ct. Memo LEXIS 319; 46 T.C.M. (CCH) 1039; T.C.M. (RIA) 83472;
August 11, 1983.
In 1974 and 1975, P was a dealer in used cars, and many of the sales were made on credit. P held the notes and reported the payments thereon as income when he received them. Held, P must report the income from the sale of cars by the accrual method and must report the face amount of the notes as income when received. Held, further, P is entitled to…
2Cases cited32 opinions
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Commissioner v. HansenSupreme Court of the United States · 1959
- Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
- Caldwell v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. CaldwellCourt of Appeals for the Second Circuit · 1953
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