Heer-Andres Inv. Co. v. Commissioner
United States Tax Court
In a prior proceeding, reported at 17 T. C. 786, it was held that certain additional rent was income to the petitioner, reporting income on the accrual basis, for the year with respect to which it was due, and not for the succeeding year when it was payable.
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In a prior proceeding, reported at 17 T. C. 786, it was held that certain additional rent was income to the petitioner, reporting income on the accrual basis, for the year with respect to which it was due, and not for the succeeding year when it was payable. It was further held that additional rent for the taxable year 1945, reported by petitioner as income for the taxable year 1946, was not includible as income for the taxable year 1946 and that only rent for the latter year was includible in income for such year. Subsequently the respondent, purporting to proceed under the provisions of…
1Opinion of the Court
OPINION.
Withey, Judge:
The respondent determined deficiencies in petitioner’s income tax in the amount of $17,457.20 and in declared value excess-profits tax in the amount of $5,336.34 for the taxable year ended January 31, 1945. The issue for decision is -whether the adjustment made by the respondent is authorized by section 3801 (b) (3) of the Internal Revenue Code.
All of the facts have been stipulated and are so found.
Petitioner is a Missouri corporation located in Springfield, Missouri. It filed its tax returns for the year ended January 31, 1945, with the collector for the sixth district…
2Cases cited8 opinions
- Commissioner of Internal Revenue v. Mnookin's EstateCourt of Appeals for the Eighth Circuit · 1950
- Mnookin v. CommissionerUnited States Tax Court · 1949
- Frame v. CommissionerUnited States Tax Court · 1951
- Brennen v. CommissionerUnited States Tax Court · 1953
- Heer-Andres Inv. Co. v. CommissionerUnited States Tax Court · 1951
3 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Kent Homes, Inc. v. CommissionerUnited States Tax Court · 1971
- Olaf E. Taxeraas, Administrator of the Estate of Carl Taxeraas and Irene Taxeraas v. United StatesCourt of Appeals for the Eighth Circuit · 1959
- Alling v. CommissionerUnited States Tax Court · 1994
- Commissioner of Internal Revenue v. Estate of GoldsteinCourt of Appeals for the Second Circuit · 1965
- Estate of Ochs v. CommissionerUnited States Tax Court · 1966
6 more not listed; retrieve them via the Exa API.