Etheridge & Vanneman, Inc. v. Commissioner
United States Tax Court
Held, that the servicing contract between petitioner and Bowery Savings Bank effective during petitioner's fiscal years ending June 30, 1955, June 30, 1956, and June 30, 1957, did not give rise to accruals as of the end of said respective fiscal years in excess of the actual payments at level payment rates made to it by the Bowery Savings Bank pursuant to said servicing contract.
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Held, that the servicing contract between petitioner and Bowery Savings Bank effective during petitioner's fiscal years ending June 30, 1955, June 30, 1956, and June 30, 1957, did not give rise to accruals as of the end of said respective fiscal years in excess of the actual payments at level payment rates made to it by the Bowery Savings Bank pursuant to said servicing contract. Guarantee Title & Trust Co. v. Commissioner, 313 F. 2d 225 (C.A. 6, 1963), reversing a Memorandum Opinion of this Court, followed.
1Opinion of the Court
Etheridge and Vanneman, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Etheridge & Vanneman, Inc. v. Commissioner
Docket No. 86895
United States Tax Court
40 T.C. 461; 1963 U.S. Tax Ct. LEXIS 108;
June 3, 1963, Filed
Decision will be entered under Rule 50.
Held, that the servicing contract between petitioner and Bowery Savings Bank effective during petitioner's fiscal years ending June 30, 1955, June 30, 1956, and June 30, 1957, did not give rise to accruals as of the end of said respective fiscal years in excess of the actual payments at level payment rates made to it by the…
2Cases cited5 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Commissioner v. HansenSupreme Court of the United States · 1959
- J. H. Schaeffer, Jr., and Opal R. Schaeffer v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1958
- The Guarantee Title and Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1963
- Etheridge & Vanneman, Inc. v. CommissionerUnited States Tax Court · 1963