Pacific Vegetable Oil Corp. v. Commissioner
United States Tax Court
1. Held, the revision effected by petitioner in 1949 to reflect contract sales accounts under which 95 per cent payments had been made in 1949 and for which contingent adjustments might be made in 1950 upon the determination in 1950 of certain facts constituted a change in its accrual method of accounting for which prior consent of the Commissioner was required.
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1. Held, the revision effected by petitioner in 1949 to reflect contract sales accounts under which 95 per cent payments had been made in 1949 and for which contingent adjustments might be made in 1950 upon the determination in 1950 of certain facts constituted a change in its accrual method of accounting for which prior consent of the Commissioner was required. Held, further, that respondent's action in rejecting the change and his requirement that the method of accounting employed by petitioner prior to 1949 be continued, is not proven to be arbitrary or an abuse of the Commissioner's…
1Opinion of the Court
OPINION.
HaRRON, Judge:
Issue 1.
The petitioner keeps its hooks and reports its income on an accrual method of accounting. Prior to 1949, with respect to income from sales of copra under a standard copra sales contract, petitioner accrued the entire invoice amount of such contracts in the year of the contract and it did so with respect to its year-end contracts where copra was in transit and the landed weights thereof had not been determined prior to the end of the taxable year. The problem under this issue relates to contracts executed in the latter part of 1949 which we refer to as year-end…
2Cases cited23 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Brown v. HelveringSupreme Court of the United States · 1934
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Continental Tie & Lumber Co. v. United StatesSupreme Court of the United States · 1932
18 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Pacific Vegetable Oil Corp. v. CommissionerUnited States Tax Court · 1956