Legal Opinion

South Texas Lumber Co. v. Commissioner

United States Tax Court

Decided August 30, 1946No. Docket No. 10050Published

Petitioner, a corporation which kept its books and filed its income and excess profits tax returns on the accrual basis, elected to compute and report the profit on installment sales of real estate made by it on the installment basis in accordance with section 44 (b), I. R. C.Held, petitioner's anticipated and unreported income from installment sales as of the beginning of the years 1941, 1942, and 1943 is not includible as part of its "accumulated earnings and profits" in…

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Petitioner, a corporation which kept its books and filed its income and excess profits tax returns on the accrual basis, elected to compute and report the profit on installment sales of real estate made by it on the installment basis in accordance with section 44 (b), I. R. C.Held, petitioner's anticipated and unreported income from installment sales as of the beginning of the years 1941, 1942, and 1943 is not includible as part of its "accumulated earnings and profits" in arriving at its equity invested capital within the meaning of section 718 (a) (4), I. R. C.

1Opinion of the Court

South Texas Lumber Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

South Texas Lumber Co. v. Commissioner

Docket No. 10050

United States Tax Court

7 T.C. 669; 1946 U.S. Tax Ct. LEXIS 88;

August 30, 1946, Promulgated

Judgment will be entered for the respondent.

Petitioner, a corporation which kept its books and filed its income and excess profits tax returns on the accrual basis, elected to compute and report the profit on installment sales of real estate made by it on the installment basis in accordance with section 44 (b), I. R. C.Held, petitioner's anticipated and unreported…

2Cases cited3 opinions

  1. Kimbrell's Home Furnishings, Inc. v. CommissionerUnited States Tax Court · 1946
  2. Federal Union Ins. Co. v. CommissionerUnited States Tax Court · 1945
  3. South Texas Lumber Co. v. CommissionerUnited States Tax Court · 1946

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