H. F. Campbell Co. v. Commissioner
United States Tax Court
From 1954 through 1961 petitioner used a type of completed-contract method, which employed the following criteria to determine when gross income from its long-term contracts was to be included in computing its taxable income: (1) Physical completion, (2) customer acceptance, (3) recordation of all costs, and (4) computation of the final bill. After an audit of its returns for 1960 and 1961 was begun, petitioner reported its income for 1962 using only the first two criteria.
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From 1954 through 1961 petitioner used a type of completed-contract method, which employed the following criteria to determine when gross income from its long-term contracts was to be included in computing its taxable income: (1) Physical completion, (2) customer acceptance, (3) recordation of all costs, and (4) computation of the final bill. After an audit of its returns for 1960 and 1961 was begun, petitioner reported its income for 1962 using only the first two criteria. Held, utilization of only the two criteria in 1962 constituted a change in petitioner's method of accounting, for which…
1Opinion of the Court
H. F. Campbell Company (formerly H. F. Campbell Construction Company), Petitioner v. Commissioner of Internal Revenue, Respondent *
H. F. Campbell Co. v. Commissioner
Docket No. 6010-64
United States Tax Court
53 T.C. 439; 1969 U.S. Tax Ct. LEXIS 7;
December 23, 1969, Filed
Decision will be entered under Rule 50.
From 1954 through 1961 petitioner used a type of completed-contract method, which employed the following criteria to determine when gross income from its long-term contracts was to be included in computing its taxable income: (1) Physical completion, (2) customer acceptance, (3) recordation…
2Cases cited26 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Fruehauf Trailer Co. v. CommissionerUnited States Tax Court · 1964
- Pursell v. CommissionerUnited States Tax Court · 1962
- Commissioner of Internal Revenue v. DwyerCourt of Appeals for the Second Circuit · 1953
- Commissioner of Internal Revenue v. O. Liquidating CorporationCourt of Appeals for the Third Circuit · 1961
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