Vanguard Recording Soc. v. Commissioner
United States Tax Court
Beginning with the fiscal year ended Apr. 30, 1957, petitioner's books show that each year up to 1963 the control account in the general ledger of accounts payable exceeded the subsidiary schedule of accounts payable by the sum of $ 8,475.75. In the fiscal year ended Mar. 31, 1963, petitioner debited its accounts payable by $ 8,475.75 and credited its earned surplus by the same sum.
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Beginning with the fiscal year ended Apr. 30, 1957, petitioner's books show that each year up to 1963 the control account in the general ledger of accounts payable exceeded the subsidiary schedule of accounts payable by the sum of $ 8,475.75. In the fiscal year ended Mar. 31, 1963, petitioner debited its accounts payable by $ 8,475.75 and credited its earned surplus by the same sum. Held, respondent was justified in assuming this accounts payable item in the sum of $ 8,475.75 had once been deducted and in the absence of proof to the contrary respondent was right in determining petitioner…
1Opinion of the Court
MtjlRONey, Judge:
Respondent determined a deficiency in petitioner’s income tax for the taxable year ended March 31, 1963, in the amount of $4,407.40.
The issue is: Did petitioner receive $8,475.75 income when it credited its earned surplus by that sum and debited its accounts payable by the same sum?
FINDINGS OF FACT
■Some of the facts have been stipulated and they are found accordingly.
Petitioner is a New York corporation with its office and principal place of business in New York City at the time it filed its petition. It filed its income tax return for the period ended March 31, 1963, with…
2Cases cited6 opinions
- Block v. CommissionerUnited States Board of Tax Appeals · 1939
- Union Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1940
- North American Coal Corp. v. Commissioner of Int. Rev.Court of Appeals for the Sixth Circuit · 1938
- Fidelity-Philadelphia Trust Co. v. CommissionerUnited States Tax Court · 1954
- Lime Cola Co. v. CommissionerUnited States Tax Court · 1954
1 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Vanguard Recording Society v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Rosenberg v. CommissionerUnited States Tax Court · 1970
- Wott v. CommissionerUnited States Tax Court · 1986
- Vanguard Recording Soc. v. CommissionerUnited States Tax Court · 1969