Long v. Commissioner
United States Tax Court
Held, petitioner's motion to reconsider our opinion in Long v. Commissioner, 93 T.C. 5 (1989), is denied, as the doctrine of constructive payment is inapplicable to the satisfaction of an account receivable established pursuant to Rev. Proc. 65-17, 1965-1 C.B. 833.
1Opinion of the Court
William R. Long, Petitioner v. Commissioner of Internal Revenue, Respondent
Long v. Commissioner
Docket No. 36064-87
United States Tax Court
93 T.C. 352; 1989 U.S. Tax Ct. LEXIS 126; 93 T.C. No. 30;
September 13, 1989September 13, 1989, Filed
Held, petitioner's motion to reconsider our opinion in Long v. Commissioner, 93 T.C. 5 (1989), is denied, as the doctrine of constructive payment is inapplicable to the satisfaction of an account receivable established pursuant to Rev. Proc. 65-17, 1965-1 C.B. 833.
Frank P. Meadows, Jr., for the petitioner.
James E. Gray, for the respondent.
Whitaker, Judge.
WHITAK…
2Cases cited4 opinions
- F. D. Bissett & Son, Inc. v. CommissionerUnited States Tax Court · 1971
- White v. CommissionerUnited States Tax Court · 1974
- Long v. CommissionerUnited States Tax Court · 1989
- Long v. CommissionerUnited States Tax Court · 1989