Charles Schwab Corp. v. Commissioner
United States Tax Court
P, an accrual basis taxpayer, provides discount securities brokerage services for which it earns a commission fee. As a discount broker, P does not engage in activities, such as research and portfolio management, that are normally conducted by a full-service broker.
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P, an accrual basis taxpayer, provides discount securities brokerage services for which it earns a commission fee. As a discount broker, P does not engage in activities, such as research and portfolio management, that are normally conducted by a full-service broker. P executes a customer's order to buy or sell securities on the trade date, but the securities are not actually transferred and payment is not due until the settlement date, which was generally 5 days after the trade date. Between those dates, P performs certain functions to record, confirm, and book the customer's trade. P…
1Opinion of the Court
Ruwe, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes for the taxable years ending March 31 and December 31, 1988, in the amounts of $16,136,176 and $12,146,497, respectively.
After concessions, the issues remaining for decision are: (1) Whether petitioner must accrue brokerage commission income on the date a trade is executed or on the settlement date; and (2) whether petitioner is entitled to a deduction for its California franchise tax liability in the amount of $932,979 on its Federal income tax return for the 9-month period ending December 31, 1988.
Unless…
2Cases cited17 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Brown v. HelveringSupreme Court of the United States · 1934
- Commissioner v. HansenSupreme Court of the United States · 1959
- Schulde v. CommissionerSupreme Court of the United States · 1963
- Continental Tie & Lumber Co. v. United StatesSupreme Court of the United States · 1932
12 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- Keith v. CommissionerUnited States Tax Court · 2000
- Charles Schwab Corp. v. Comm'rUnited States Tax Court · 2004
- Charles Schwab Corp. v. Comm'rUnited States Tax Court · 2004
- Massachusetts Mutual Life Insurance v. United StatesUnited States Court of Federal Claims · 2012
- Trinity Indus. v. Comm'rUnited States Tax Court · 2009
20 more not listed; retrieve them via the Exa API.