Dorr-Oliver, Inc. v. Commissioner
United States Tax Court
Without seeking or receiving the permission of the Commissioner, petitioner's predecessor accrued vacation pay under certain union agreements amounting to approximately $ 25,000 in 1954. It had previously treated all vacation pay under these agreements on the cash basis during the several years in which such agreements were in effect.
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Without seeking or receiving the permission of the Commissioner, petitioner's predecessor accrued vacation pay under certain union agreements amounting to approximately $ 25,000 in 1954. It had previously treated all vacation pay under these agreements on the cash basis during the several years in which such agreements were in effect. Held, under these circumstances accrual of such vacation pay was a change in accounting method which could not be employed without the consent of the Commissioner. American Can Co., 37 T.C. 198, involving the 1939 Code, distinguished.
1Opinion of the Court
OPINION
FORRESTER, Judge:
Respondent has determined a deficiency of $12,-952.28 in income tax for the taxable year 1954. The sole issue is whether the deduction of certain accrued vacation pay constituted a change in method of accounting without the prior consent of respondent.
All of the facts have been stipulated and are so found.
Petitioner, Dorr-Oliver Inc., is a corporation organized and existing under the laws of the State of Delaware. It is the successor to Oliver United Filters Inc., a corporation organized under the laws of the State of Nevada, and will hereinafter be referred to as…
2Cases cited3 opinions
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- American Can Co. v. CommissionerUnited States Tax Court · 1961
- Marquardt Corp. v. CommissionerUnited States Tax Court · 1962
3Cited by19 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- North Carolina Granite Corp. v. CommissionerUnited States Tax Court · 1964
- Herbert S. Witte v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1975
- Turtle Wax, Inc. v. CommissionerUnited States Tax Court · 1965
- Ryan v. CommissionerUnited States Tax Court · 1964
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