Legal Opinion

Battelle v. Commissioner

United States Tax Court

Decided September 9, 1947No. Docket Nos. 8944, 8945Published

1. Under the provisions of section 19.22 (c)-6, Regulations 103, petitioner elected to change the basis of his return for the year 1941 from that of receipts and disbursements to that of an inventory basis and followed precisely the method of adjustment required by that section. Prior to the change he did not seek or obtain the Commissioner's permission therefor.

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1. Under the provisions of section 19.22 (c)-6, Regulations 103, petitioner elected to change the basis of his return for the year 1941 from that of receipts and disbursements to that of an inventory basis and followed precisely the method of adjustment required by that section. Prior to the change he did not seek or obtain the Commissioner's permission therefor. Held, that petitioner was not required to obtain the Commissioner's permission before making such change. 2. In computing the proportion of petitioner's income attributable to community property sources, Clara B. Parker, 31 B. T. A.…

1Opinion of the Court

Kenneth S. Battelle, Petitioner, v. Commissioner of Internal Revenue, Respondent. Cora E. Battelle, Petitioner, v. Commissioner of Internal Revenue, Respondent

Battelle v. Commissioner

Docket Nos. 8944, 8945

United States Tax Court

9 T.C. 299; 1947 U.S. Tax Ct. LEXIS 114;

September 9, 1947, Promulgated

Decisions will be entered under Rule 50.

1. Under the provisions of section 19.22 (c)-6, Regulations 103, petitioner elected to change the basis of his return for the year 1941 from that of receipts and disbursements to that of an inventory basis and followed precisely the method of adjustment…

2Cases cited4 opinions

  1. United States v. ChaseSupreme Court of the United States · 1890
  2. Todd v. CommissionerUnited States Tax Court · 1946
  3. Battelle v. CommissionerUnited States Tax Court · 1947
  4. Tinling v. CommissionerUnited States Tax Court · 1946

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