National Bread Wrapping Machine Co. v. Commissioner
United States Tax Court
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.
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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
- United States v. AndersonSupreme Court of the United States · 1926
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Waterman v. MacKenzieSupreme Court of the United States · 1891
- Brown v. HelveringSupreme Court of the United States · 1934
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
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