Johnson v. Commissioner
United States Tax Court
Amounts withheld by finance companies out of sums due on purchase of notes from petitioner, an accrual basis trailer dealer, which amounts were held as "dealer's reserves" and credited to petitioner's account on the finance companies' books, held, includible in petitioner's taxable income.
1Opinion of the Court
OPINION.
Opper, Judge:
Respondent determined the deficiencies here involved by restoring to petitioner’s net income the “dealer reserves” withheld by finance companies from trailer paper they bought from petitioner. This determination, -which is supported by Shoemaker-Nash, Inc., 41 B. T. A. 417, the only published opinion of this tribunal dealing with the present question, is resisted by petitioner, an accrual basis taxpayer,1 on the ground that that case is distinguishable for the reason that dealer reserves in the automobile financing field differ from those in the trailer field. Though the…
2Cases cited3 opinions
- Herberger v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1952
- Keasbey & Mattison Co. v. United StatesCourt of Appeals for the Third Circuit · 1944
- Rhode Island Hospital T. Co. v. COM'NR. OF INTERNAL REVENUECourt of Appeals for the First Circuit · 1928
3Cited by12 opinions
- Texas Trailercoach, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
- Clifton E. Baird and Violet L. Baird v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1958
- Morgan v. CommissionerUnited States Tax Court · 1957
- Kilborn v. CommissionerUnited States Tax Court · 1957
- Texas Trailercoach, Inc. v. CommissionerUnited States Tax Court · 1956
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