Commissioner of Internal Revenue v. Robert J. And Emma R. Stuatr

One of the reasons for adopting the installment plan of reporting income was to relieve taxpayers from having to pay an income tax in the year of sale based on the full amount of anticipated profits when in the tax year they received in cash only a small part of the sales price. Commissioner of Internal Revenue v. South Texas Lumber Co., 333 U.S. 496, 68 S.Ct. 695, 92 L.Ed. 831 (1948). Section 453 being remedial, “manifestly it is to be construed liberally in favor of the taxpayers to give the relief it was intended to provide.” Bonwit Teller & Co. v. United States, 283 U.S. 258, 263, 51…