C. H. Leavell & Co. v. Commissioner
United States Tax Court
Petitioner was a member of a joint venture organized to perform a single construction contract. The joint venture computed its taxable income under the completed contract method of accounting.
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Petitioner was a member of a joint venture organized to perform a single construction contract. The joint venture computed its taxable income under the completed contract method of accounting. Held, the joint venture reported its income on the basis of a calendar, rather than a fiscal year; held, further, the existence of contingent claims for additional compensation did not cause the time for reporting the joint venture's gross income from the contract to be deferred beyond the year in which the contract was "finally completed and accepted"; held, further, the execution of a Form 875 does…
1Opinion of the Court
FeatheRSton, Judge:
Respondent determined deficiencies in petitioner’s income tax for its taxable years ending March 31, 1963 and 1965, in the amounts of $116,723.43 and $699, respectively, and found an overassessment for the year ending March 31, 1964, in the amount of $3,569.55.
Certain issues have been settled; the issues presented for decision are:(1) Whether a joint venture, of which petitioner was a member, computed its taxable income on the basis of a calendar year or a fiscal year.(2) Whether a contract undertaken by the joint venture was finally completed and accepted in 1960.(3)…
2Cases cited21 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Standard Paving Co. v. Commissioner of Internal Revenue. Standard Paving Co. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1951
- National Contracting Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1939
- Standard Paving Co. v. CommissionerUnited States Tax Court · 1949
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