Tecumseh Corrugated Box Company v. Commissioner of Internal Revenue

RALPH B. GUY, Jr., Circuit Judge.

Petitioner, Tecumseh Corrugated Box Company (petitioner, taxpayer, or Tecumseh), appeals from a Tax Court decision finding in favor of respondent, Commissioner of Internal Revenue (respondent or Commissioner). The Tax Court held that petitioner could not use the installment method to account for capital gains resulting from the sale of its properties. 94 T.C. 360.

Petitioner argues that the Tax Court erred because the sale of one of its properties took place under the threat of condemnation. Thus, petitioner was still entitled to account for its capital gains…