Andrews v. Commissioner
United States Tax Court
1. Petitioner Curtis R. Andrews and another individual formed a partnership in 1938, which thereafter conducted several dancing schools. The partnership kept its books on the accrual system. It treated prepaid tuition receipts as deferred income, reporting as income each year that portion of the receipts which represented lessons taught during the year.
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1. Petitioner Curtis R. Andrews and another individual formed a partnership in 1938, which thereafter conducted several dancing schools. The partnership kept its books on the accrual system. It treated prepaid tuition receipts as deferred income, reporting as income each year that portion of the receipts which represented lessons taught during the year. When the partnership was terminated in 1948, it had prepaid tuition receipts in the amount of $ 272,958.80 in its Unearned Tuition account, which had not yet been taken into income. Petitioner operated one of the schools as a sole proprietor…
1Opinion of the Court
OPINION.
Rice, Judge:
The first issue to be decided is the correctness of respondent’s determination that the entire amount of the partnership’s advance tuition fees must be included in income in the year of receipt, regardless of the number of prepaid lessons remaining to be taught at the end of such year. Petitioner argues that an accrual basis taxpayer’s treatment of prepaid tuition receipts as deferred income is in accord with generally accepted accounting practice and that respondent erred in determining that, as a matter of law, such system failed to clearly reflect income.
Irrespective of…
2Cases cited10 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Brown v. HelveringSupreme Court of the United States · 1934
- Beacon Publishing Company, a Kansas Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1955
- Johnston v. CommissionerUnited States Tax Court · 1950
- Your Health Club, Inc. v. CommissionerUnited States Tax Court · 1944
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3Cited by10 opinions
- E. W. Schuessler and Aline Schuessler v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1956
- Mark E. Schlude and Marzalie Schlude, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1960
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- Andrews v. CommissionerUnited States Tax Court · 1955
5 more not listed; retrieve them via the Exa API.