Hughes v. Commissioner
United States Tax Court
From January 1, 1944, through the taxable year 1947 the petitioners were members of a partnership which reported its income on the cash basis. The purchase and sale of merchandise was an income producing factor of the partnership business during 1947 and prior years.
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From January 1, 1944, through the taxable year 1947 the petitioners were members of a partnership which reported its income on the cash basis. The purchase and sale of merchandise was an income producing factor of the partnership business during 1947 and prior years. For 1947 the respondent recomputed the partnership's income on the accrual basis of accounting and in doing so included in income the accounts receivable which were outstanding at the beginning of the year and which had accrued in 1946 and prior years. Held, respondent's inclusion in the partnership income for 1947 of accounts…
1Opinion of the Court
OPINION.
Withet, Judge:
The partnership reported its income for 1947 on the cash basis. The Commissioner has recomputed its income for that year on the accrual basis. In so doing he has included in income that portion of partnership accounts receivable which remained uncollected at the close of 1946 and at the beginning of 1947. Respondent claims the authority for so doing under E. S. Iley, 19 T. C. 631, and William Hardy, Inc. v. Commissioner, (C. A. 2, 1936) 82 F. 2d 249.
We do not consider the fact that the partnership may have kept its business records on the wrong basis to be particularly…
2Cases cited4 opinions
- Caldwell v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. CaldwellCourt of Appeals for the Second Circuit · 1953
- Commissioner of Internal Revenue v. DwyerCourt of Appeals for the Second Circuit · 1953
- William Hardy, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1936
- Commons v. CommissionerUnited States Tax Court · 1953
3Cited by27 opinions
- SoRelle v. CommissionerUnited States Tax Court · 1954
- Fruehauf Trailer Co. v. CommissionerUnited States Tax Court · 1964
- Pursell v. CommissionerUnited States Tax Court · 1962
- Hartley v. CommissionerUnited States Tax Court · 1954
- Ezo Products Co. v. CommissionerUnited States Tax Court · 1961
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