Hagen Advertising Displays, Inc., an Ohio Corporation v. Commissioner of Internal Revenue

McCREE, Circuit Judge.

This is a petition to review a decision of the Tax Court upholding the Commissioner’s determination that taxpayer must include advance payments from its customers in its gross income in the year of receipt.

Hagen Advertising Displays, Inc., petitioner-taxpayer, is a manufacturer of advertising signs with its principal office in Cincinnati, Ohio. Many of petitioner’s customers are engaged in establishing new dealerships throughout the country and require a continuous supply of illuminated, plastic, dealer-identification signs. It was the practice of such customers, during…