Marcor, Inc. v. Commissioner
United States Tax Court
Ward, a member of P's consolidated group, is an accrual basis taxpayer which reports its income from installment credit sales pursuant to the provisions of sec. 453, I.R.C. 1954. Ward is a dealer in personal property which sells merchandise at retail through its mail order catalogs and department stores. Some of the merchandise Ward sells requires installation or "preparation" (e.g., assembly, alteration) prior to its use by the customer.
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Ward, a member of P's consolidated group, is an accrual basis taxpayer which reports its income from installment credit sales pursuant to the provisions of sec. 453, I.R.C. 1954. Ward is a dealer in personal property which sells merchandise at retail through its mail order catalogs and department stores. Some of the merchandise Ward sells requires installation or "preparation" (e.g., assembly, alteration) prior to its use by the customer. Ward provides installation and preparation services to the customer for its merchandise, though all merchandise may be purchased without installation or…
1Opinion of the Court
WILLIAMS, Judge-*
These consolidated cases are before the Court on the parties’ cross-motions for partial summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure.
The Commissioner determined deficiencies in Federal income tax for petitioner’s taxable years ended January 31 of 1972, 1973, 1974, 1975, and 1976 and the short taxable year ended July 1, 1976, as follows:
Docket No. TYE— Deficiency
13037-82 Jan. 31, 1972 $6,694,810
Jan. 31, 1973 4,014,231
Jan. 31, 1974 3,455,772
29876-82 Jan. 31, 1975 7,695,893
Jan. 31, 1976 17,307,164
July 1, 1976 26,200,669
The issues this Court…
2Cases cited16 opinions
- Federal Land Bank of St. Paul v. Bismarck Lumber Co.Supreme Court of the United States · 1941
- First Agricultural National Bank of Berkshire County v. State Tax CommissionSupreme Court of the United States · 1968
- Blair v. Oesterlein MacHine Co.Supreme Court of the United States · 1927
- Helvering v. Cement Investors, Inc.Supreme Court of the United States · 1942
- Laurence M. And Phyllis W. Carlson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
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3Cited by3 opinions
- Patients Mutual Assistance Collective Corporation d.b.a. Harborside Health Center v. CommissionerUnited States Tax Court · 2018
- Patients Mutual Assistance Collective Corporation d.b.a. Harborside Health Center v. CommissionerUnited States Tax Court · 2018
- Marcor, Inc. v. CommissionerUnited States Tax Court · 1987