Amalgamated Sugar Co. v. Commissioner
United States Board of Tax Appeals
1. The consistent accounting practice of a seller of fungible goods to accrue the price fixed by its sales contracts as income in the year of the contract, when the evidence shows that all parties in the trade regard title to the goods as passing at that time and not at the time of later delivery and payment, held correctly to reflect income. 2. The significance of a form of contract as part of a system of carrying on business may be determined by reference to the usages by…
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1. The consistent accounting practice of a seller of fungible goods to accrue the price fixed by its sales contracts as income in the year of the contract, when the evidence shows that all parties in the trade regard title to the goods as passing at that time and not at the time of later delivery and payment, held correctly to reflect income. 2. The significance of a form of contract as part of a system of carrying on business may be determined by reference to the usages by which its terms are commonly understood and interpreted by the parties themselves, and evidence of such usages held…
1Opinion of the Court
APPEAL OF THE AMALGAMATED SUGAR CO.
Amalgamated Sugar Co. v. Commissioner
Docket No. 6439.
United States Board of Tax Appeals
4 B.T.A. 568; 1926 BTA LEXIS 2248;
July 30, 1926, Decided
1. The consistent accounting practice of a seller of fungible goods to accrue the price fixed by its sales contracts as income in the year of the contract, when the evidence shows that all parties in the trade regard title to the goods as passing at that time and not at the time of later delivery and payment, held correctly to reflect income.
2. The significance of a form of contract as part of a system of carrying on…
2Cases cited3 opinions
- Kimberly v. . PatchinNew York Court of Appeals · 1859
- B. B. Todd, Inc. v. CommissionerUnited States Board of Tax Appeals · 1925
- Amalgamated Sugar Co. v. CommissionerUnited States Board of Tax Appeals · 1926