Legal Opinion
Commissioner of Internal Revenue v. Schuyler
Court of Appeals for the Second Circuit
Decided April 14, 1952No. 22222_1PublishedCited by 43 opinions
1Opinion of the Court
SWAN, Chief Judge.
For the taxable year 1947, the Commissioner required the taxpayers to change from the cash basis of reporting income to the accrual basis, on which their books were kept, and included in gross income the closing inventory of the year but disallowed the deduction of the opening inventory. The Tax Court permitted the taxpayers to deduct the opening inventory. The correctness of this ruling is the sole question presented.
The facts are undisputed. Since 1926 the taxpayers, husband and wife, have owned and operated the Naples Hotel in Naples, New York. In connection with the…
2Cases cited9 opinions
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Commissioner of Internal Revenue v. Mnookin's EstateCourt of Appeals for the Eighth Circuit · 1950
- Greene Motor Co. v. CommissionerUnited States Tax Court · 1945
- Frame v. CommissionerUnited States Tax Court · 1951
- Commissioner of Internal Revenue v. FrameCourt of Appeals for the Third Circuit · 1952
4 more not listed; retrieve them via the Exa API.
3Cited by43 opinions
- Caldwell v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. CaldwellCourt of Appeals for the Second Circuit · 1953
- Fruehauf Trailer Co. v. CommissionerUnited States Tax Court · 1964
- Pursell v. CommissionerUnited States Tax Court · 1962
- Commissioner of Internal Revenue v. DwyerCourt of Appeals for the Second Circuit · 1953
- Josef C. Patchen and Aleyne E. Patchen v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
38 more not listed; retrieve them via the Exa API.