Legal Opinion

Permanent Homes Land Co. v. Commissioner

United States Board of Tax Appeals

Decided November 25, 1932No. Docket No. 45156Published

1. ACCRUAL SYSTEM OF ACCOUNTING - WHEN INCOME SHOULD BE ACCRUED. - Amounts agreed to be paid petitioner on account of the cancellation of an old contract and in consideration of further agreements made in a new contract, which amounts are to be paid out of the proceeds of refinancing the property involved in the transactions, are income to petitioner, on the accrual basis, in the year when the obligation to pay petitioner such amounts became definite and fixed.

Read the full summary

1. ACCRUAL SYSTEM OF ACCOUNTING - WHEN INCOME SHOULD BE ACCRUED. - Amounts agreed to be paid petitioner on account of the cancellation of an old contract and in consideration of further agreements made in a new contract, which amounts are to be paid out of the proceeds of refinancing the property involved in the transactions, are income to petitioner, on the accrual basis, in the year when the obligation to pay petitioner such amounts became definite and fixed. Lichtenberger-Ferguson Co. v. Welch, 54 Fed.(2d) 570; Continental Tie & Lumber Co. v. United States,286 U.S. 290. 2. BURDEN OF PROOF.…

1Opinion of the Court

THE PERMANENT HOMES LAND COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Permanent Homes Land Co. v. Commissioner

Docket No. 45156.

United States Board of Tax Appeals

27 B.T.A. 142; 1932 BTA LEXIS 1121;

November 25, 1932, Promulgated

1. ACCRUAL SYSTEM OF ACCOUNTING - WHEN INCOME SHOULD BE ACCRUED. - Amounts agreed to be paid petitioner on account of the cancellation of an old contract and in consideration of further agreements made in a new contract, which amounts are to be paid out of the proceeds of refinancing the property involved in the transactions, are income to…

2Cases cited3 opinions

  1. Continental Tie & Lumber Co. v. United StatesSupreme Court of the United States · 1932
  2. Permanent Homes Land Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  3. Klein v. CommissionerUnited States Board of Tax Appeals · 1930

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API