Legal Opinion

Carroll Furniture Co. v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided June 24, 1952No. 13886PublishedCited by 1 opinion

1Opinion of the Court

RIVES, Circuit Judge.

This petition for review of a decision of the Tax Court reported at 15 T.C. 943 presents for decision two questions, viz:

1. Whether the taxpayer’s gain was realized and subject to accrual at the time it purchased the accounts receivable of a separate, unrelated concern, or at the time it collected portions of those accounts.

2. Whether a taxpayer which had elected to compute its income for excess profits tax purposes on the accrual basis in accordance with Section 736(a) of the Internal Revenue Code, 26 U.S.C.A. § 736 (a), rather than on the installment basis in accordance…

2Cases cited11 opinions

  1. General Utilities & Operating Co. v. HelveringSupreme Court of the United States · 1935
  2. Palmer v. CommissionerSupreme Court of the United States · 1937
  3. Herbert's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1943
  4. Hatch v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1951
  5. Helvering v. RothCourt of Appeals for the Second Circuit · 1940

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3Cited by1 opinion

  1. In Re ProMedCo of Los CrucesUnited States Bankruptcy Court, N.D. Texas · 2002

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