Legal Opinion

National Bread Wrapping Machine Co. v. Commissioner

United States Tax Court

Decided June 10, 1958No. Docket No. 57404Published

1. Accrual Method -- Reserves for Installation. -- Reserves for installation of machines sold by the petitioner which the petitioner was obligated to install for the purchasers, but which had not been installed at the end of the year, held, not deductible for the reason that installation services had not been performed.

Read the full summary

1. Accrual Method -- Reserves for Installation. -- Reserves for installation of machines sold by the petitioner which the petitioner was obligated to install for the purchasers, but which had not been installed at the end of the year, held, not deductible for the reason that installation services had not been performed. All that had accrued was the obligation to perform services. 2. Income from Patents. -- Income representing a portion of selling price of machines manufactured and sold by a foreign company under patent rights granted by the petitioner, held to be royalty income and not…

1Opinion of the Court

National Bread Wrapping Machine Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

National Bread Wrapping Machine Co. v. Commissioner

Docket No. 57404

United States Tax Court

30 T.C. 550; 1958 U.S. Tax Ct. LEXIS 166; 117 U.S.P.Q. (BNA) 492;

June 10, 1958, Filed

Decision will be entered for the respondent.

1. Accrual Method -- Reserves for Installation. -- Reserves for installation of machines sold by the petitioner which the petitioner was obligated to install for the purchasers, but which had not been installed at the end of the year, held, not deductible for the reason that…

2Cases cited24 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
  3. Waterman v. MacKenzieSupreme Court of the United States · 1891
  4. Brown v. HelveringSupreme Court of the United States · 1934
  5. Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944

19 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API