Dana Distributors Inc. v. Commissioner of Internal Revenue

Petitioner Dana Distributors Inc. (“Dana”) appeals from a decision of the United States Tax Court, B. John Williams, Jr., Judge, upholding the rejection by respondent Commissioner of Internal Revenue (“Commissioner") of the use by Dana, a wholesale beverage distributor, of the reserve method of accounting for container deposits and handling fees. The tax court ruled that Dana was required to include in its gross income the amounts collected as deposits and handling fees in the year in which they were received and was not entitled to deduct any amount for refunds paid prior to the year in…