Lutz v. Commissioner
United States Tax Court
1. Partnership contracted to build military housing for the Government in the State of Washington under the Capehart Act. It reported its income under these contracts on an accrual and completed-contract basis of accounting. A question arose whether the Washington retail sales tax applied to the income under Capehart contracts.
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1. Partnership contracted to build military housing for the Government in the State of Washington under the Capehart Act. It reported its income under these contracts on an accrual and completed-contract basis of accounting. A question arose whether the Washington retail sales tax applied to the income under Capehart contracts. Arrangements were made with State tax commissioner whereby partnership reported its receipts under these contracts on its State excise tax returns and claimed deductions of same amounts; commissioner assessed the retail sales tax due on these receipts but agreed not to…
1Opinion of the Court
Leennen, Judge:
Respondent determined deficiencies in income tax for the taxable years in question as follows:
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Certain issues raised in the pleadings have been abandoned or settled by agreement between the parties. The two issues remaining for decision are:(1) Whether certain liabilities for State of Washington retail sales tax were contingent, and therefore not properly accruable by the partnership, General Investment Co., during the taxable years in question.(2) Whether petitioners, shareholders in the General Mortgage Agency, Inc., which elected to be taxed under subchapter S,…
2Cases cited28 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Danielson v. CommissionerUnited States Tax Court · 1965
- Ullman v. CommissionerCourt of Appeals for the Second Circuit · 1959
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3Cited by21 opinions
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
- O'Dell & Co. v. CommissionerUnited States Tax Court · 1974
- Lutz v. CommissionerCourt of Appeals for the Ninth Circuit · 1968
- Mariani Frozen Foods, Inc. v. CommissionerUnited States Tax Court · 1983
- Morris v. CommissionerUnited States Tax Court · 1968
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