Daily Record Co. v. Commissioner
United States Board of Tax Appeals
The petitioner made its income and profits-tax returns for 1921 and prior years on a cash receipts and disbursements basis. It made no material change in its bookkeeping in 1921. Held, that a return on the cash receipts and disbursements basis reflected its true net income for 1921.
1Opinion of the Court
*460OPINION.
Smith :
Section 232 of the Revenue Act of 1921 states:
That in the case of a corporation subject to the tax imposed by section 230 the term “net income” means the gross income as defined in section 233 Jess the deductions allowed by section 234, and the net income shall be computed on the same basis as is provided in subdivision (b) of section 212 * * *
Section 212 (b) provides:
The net income shall be computed upon the basis of the taxpayer’s annual accounting- period (fiscal year or calendar year, as the case may be) in accordance with the method of accounting regularly employed in…
2Cases cited2 opinions
- Southern Pac. R. v. MuenterCourt of Appeals for the Ninth Circuit · 1919
- Doyle v. Mitchell Bros.Court of Appeals for the Sixth Circuit · 1916
3Cited by4 opinions
- Reynolds Cattle Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Daily Record Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Estate of Paul Hansen v. CommissionerUnited States Tax Court · 1945
- North American Coal Corp. v. CommissionerUnited States Board of Tax Appeals · 1935