Legal Opinion

James M. Pierce Corporation v. Commissioner of Internal Revenue

Court of Appeals for the Eighth Circuit

Decided February 28, 1964No. 17265PublishedCited by 19 opinions

1Opinion of the Court

BLACKMUN, Circuit Judge.

The Tax Court has upheld the Commissioner’s determination of a deficiency in the federal income tax of James M. Pierce Corporation for its fiscal year ended June 30, 1957. Judge Mulroney’s decision, not reviewed by the full court, is reported at 38 T.C. 643. The taxpayer has petitioned for review.

The initial issue before us concerns the includability in gross income of the amount of prepaid magazine subscriptions unexpired in the taxable year during which the publication was sold and the subscription liability was assumed by the purchaser.

The Commissioner originally…

2Cases cited40 opinions

  1. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  2. Crane v. CommissionerSupreme Court of the United States · 1947
  3. Douglas v. WillcutsSupreme Court of the United States · 1935
  4. Tyler v. United StatesSupreme Court of the United States · 1930
  5. Commissioner v. HansenSupreme Court of the United States · 1959

35 more not listed; retrieve them via the Exa API.

3Cited by19 opinions

  1. John P. Scripps Newspapers v. CommissionerUnited States Tax Court · 1965
  2. Bremerton Sun Publishing Co. v. CommissionerUnited States Tax Court · 1965
  3. Focht v. CommissionerUnited States Tax Court · 1977
  4. Kurio v. United StatesDistrict Court, S.D. Texas · 1970
  5. Sandy Estate Co. v. CommissionerUnited States Tax Court · 1964

14 more not listed; retrieve them via the Exa API.

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