Pursell v. Commissioner
United States Tax Court
Petitioners kept their books and records on the accrual basis, which clearly reflected their income. For the calendar years 1950-1953 petitioners reported and computed their income on their tax returns on the cash basis, without using inventories, receivables, or payables. On their tax returns for 1954 and subsequent years petitioners reported and computed their income on the accrual basis consistent with their books and records.
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Petitioners kept their books and records on the accrual basis, which clearly reflected their income. For the calendar years 1950-1953 petitioners reported and computed their income on their tax returns on the cash basis, without using inventories, receivables, or payables. On their tax returns for 1954 and subsequent years petitioners reported and computed their income on the accrual basis consistent with their books and records. Respondent adjusted petitioners' income for 1954 and subsequent years by adding back to income opening inventories and accounts receivable and deducting accounts…
1Opinion of the Court
DRennen, Judge:
Respondent determined deficiencies in income tax due from petitioners for the taxable years and in the amounts as follows:
Year Amounts
1954_$12,456.24
1955_ 10,687.55
1956_ 9,696.09
1957_ 8, 092. 59
1958_ 10,640.51
The issues for decision are:(1) Whether petitioners changed their method of accounting in 1954 within the meaning of section 481 of the Internal Eevenue Code of 1954.1(2) Whether section 29 of the Technical Amendments Act of 1958, which amended section 481 of the Internal Eevenue Code, is constitutional.(3) If petitioners changed their method of accounting in 1954, whether…
2Cases cited19 opinions
- Commissioner of Internal Revenue v. DwyerCourt of Appeals for the Second Circuit · 1953
- Ezo Products Co. v. CommissionerUnited States Tax Court · 1961
- Commissioner of Internal Revenue v. SchuylerCourt of Appeals for the Second Circuit · 1952
- Frame v. CommissionerUnited States Tax Court · 1951
- Commissioner of Internal Revenue v. FrameCourt of Appeals for the Third Circuit · 1952
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3Cited by63 opinions
- Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
- Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
- Schuster's Express, Inc. v. CommissionerUnited States Tax Court · 1976
- Dearborn Gage Co. v. CommissionerUnited States Tax Court · 1967
- Grunwald v. CommissionerUnited States Tax Court · 1986
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