Legal Opinion

Wilkins Pontiac v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Wilkins Pontiac

Court of Appeals for the Ninth Circuit

Decided December 26, 1961No. 17299PublishedCited by 24 opinions

1Opinion of the Court

MERRILL, Circuit Judge.

Wilkins Pontiac, engaged in the operation of an automobile dealership in Van Nuys, California, has petitioned this court to review a decision of the Tax Court determining a deficiency in federal income tax for the year 1955.

In the course of its business, petitioner sold automobiles and received conditional sales contracts covering the balance due. Petitioner assigned these contracts to GMAC for the full face value without discount and guaranteed payment of the full amount due under the contracts. Petitioner since 1947 has maintained a reserve for losses sustained by…

2Cases cited2 opinions

  1. Putnam v. CommissionerSupreme Court of the United States · 1956
  2. Wilkins Pontiac v. CommissionerUnited States Tax Court · 1960

3Cited by24 opinions

  1. Western Oaks Bldg. Corp. v. CommissionerUnited States Tax Court · 1968
  2. Glenn L. Bolling and Ila L. Bolling, Mae L. Hausmann, Fairhills Company, B & H Homes, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1966
  3. Burbank Liquidating Corp. v. CommissionerUnited States Tax Court · 1963
  4. Foster Frosty Foods, Inc. v. CommissionerUnited States Tax Court · 1963
  5. Foster Frosty Foods, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1964

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