Vance L. Wiley v. Commissioner of Internal Revenue, Frank D. Wiley v. Commissioner of Internal Revenue

In Schaeffer v. Commissioner, 6 Cir., 258 F.2d 861, we held that certain “hold-backs” by a finance company from the proceeds of a note executed by the purchaser of an automobile to the automobile dealer and sold by the dealer to the finance company, which “hold-backs” were credited in a dealer’s reserve account on the books of the finance company, constituted accrued income to the dealer, who made return of income on the accrual basis, at the time of the transaction. The petitions for review of decisions of the Tax Court, which are now before us, present the same basic question and are…