Argo Sales Co. v. Commissioner
United States Tax Court
T, a corporation, made an application to change its method of accounting in 1985. The change in accounting method required a sec. 481(a) adjustment to income, which, pursuant to Rev. Proc. 85-36, 1985-2 C.B. 434, T was permitted to spread over 6 years. T included one-sixth of the sec. 481(a) adjustment in its corporate income in each of its fiscal years ended Mar. 31, 1986 through 1988. Effective Apr. 1, 1988, T elected to convert to an S corporation.
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T, a corporation, made an application to change its method of accounting in 1985. The change in accounting method required a sec. 481(a) adjustment to income, which, pursuant to Rev. Proc. 85-36, 1985-2 C.B. 434, T was permitted to spread over 6 years. T included one-sixth of the sec. 481(a) adjustment in its corporate income in each of its fiscal years ended Mar. 31, 1986 through 1988. Effective Apr. 1, 1988, T elected to convert to an S corporation. On its S corporation income tax returns for the short year ended Dec. 31, 1988, and the calendar years 1989 and 1990, T included the three…
1Opinion of the Court
ARGO SALES COMPANY, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Argo Sales Co. v. Commissioner
Docket No. 16072-93
United States Tax Court
105 T.C. 86; 1995 U.S. Tax Ct. LEXIS 43; 105 T.C. No. 7;
August 2, 1995, Filed
Decision will be entered for respondent.
T, a corporation, made an application to change its method of accounting in 1985. The change in accounting method required a sec. 481(a) adjustment to income, which, pursuant to Rev. Proc. 85-36, 1985-2 C.B. 434, T was permitted to spread over 6 years. T included one-sixth of the sec. 481(a) adjustment in its corporate…
2Cases cited10 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Jewett v. CommissionerSupreme Court of the United States · 1982
- First Chicago Corporation v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1988
- First Chicago Corp. v. CommissionerUnited States Tax Court · 1987
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