Griffith v. Commissioner
United States Tax Court
Ps, farmers who reported their income on the cash method, sold cotton in 1973 under a contract which deferred payment until later years. The purchaser's obligation under the contract was secured by a standby letter of credit. Held, Ps received in 1973 all the income from the sale, since the contractual rights and letter of credit were the equivalent of cash.
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Ps, farmers who reported their income on the cash method, sold cotton in 1973 under a contract which deferred payment until later years. The purchaser's obligation under the contract was secured by a standby letter of credit. Held, Ps received in 1973 all the income from the sale, since the contractual rights and letter of credit were the equivalent of cash. Held, further, Ps were not entitled to elect the installment method of reporting the income from the sale since, in the year of sale, they received a payment exceeding 30 percent of the price of the cotton. Sec. 453(b)(2), I.R.C. 1954.
1Opinion of the Court
J. K. Griffith and Erma Griffith, Petitioners v. Commissioner of Internal Revenue, Respondent; Curtis C. Griffith and Cynthia A. Griffith, Petitioners v. Commissioner of Internal Revenue, Respondent
Griffith v. Commissioner
Docket Nos. 4935-77, 4936-77
United States Tax Court
73 T.C. 933; 1980 U.S. Tax Ct. LEXIS 178;
February 28, 1980, Filed
Decisions will be entered for the respondent.
Ps, farmers who reported their income on the cash method, sold cotton in 1973 under a contract which deferred payment until later years. The purchaser's obligation under the contract was secured by a standby letter…
Also in this document: Concurrence; Dissent.
2Cases cited19 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Knetsch v. United StatesSupreme Court of the United States · 1960
- H. O. Williams and Mrs. Ada L. Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Pozzi v. CommissionerUnited States Tax Court · 1967
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