Legal Opinion

Southeast Equipment Corp. v. Commissioner

United States Tax Court

Decided January 22, 1960No. Docket No. 71130PublishedCited by 17 opinions

Sec. 481, I.R.C. 1954 as Amended by Technical Amendments Act of 1958 -- Adjustments Required by Change in Method of Accounting. -- Beginning with taxable year 1954 petitioner voluntarily, and without seeking the Commissioner's approval, changed its method of accounting from cash to accrual. Incident to the change petitioner in its 1954 return made certain adjustments relative to inventories and accounts receivable pertaining to pre-1954 years.

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Sec. 481, I.R.C. 1954 as Amended by Technical Amendments Act of 1958 -- Adjustments Required by Change in Method of Accounting. -- Beginning with taxable year 1954 petitioner voluntarily, and without seeking the Commissioner's approval, changed its method of accounting from cash to accrual. Incident to the change petitioner in its 1954 return made certain adjustments relative to inventories and accounts receivable pertaining to pre-1954 years. Increased income resulted to petitioner solely by reason of the adjustments necessary to prevent amounts from being duplicated or omitted. The…

1Opinion of the Court

Tietjens, Judge:

The Commissioner determined a deficiency in income tax for the year 1954 in the amount of $6,243.32.

This determination was based on adjustments for unallowable claimed deductions totaling $12,006.38 for officers’ expenses, rent, and depreciation. In the petition filed herein these adjustments were attacked as erroneous and petitioner alleged further error in including in gross income for 1954 certain items of inventory and accounts receivable incident to a change in 1954 from a cash method of accounting to an accrual method. The expense, rent, and depreciation issues have been…

2Cases cited3 opinions

  1. Penn Mut. Indem. Co. v. CommissionerUnited States Tax Court · 1959
  2. Sidney v. CommissionerUnited States Tax Court · 1958
  3. Niagara Searchlight Co. v. CommissionerUnited States Tax Court · 1953

3Cited by17 opinions

  1. Wildman v. CommissionerUnited States Tax Court · 1982
  2. Rose v. CommissionerUnited States Tax Court · 1970
  3. Pursell v. CommissionerUnited States Tax Court · 1962
  4. Ferrer v. CommissionerUnited States Tax Court · 1961
  5. Picchione v. Comm'rUnited States Tax Court · 1970

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