Iowa Guarantee Mortg. Corp. v. Commissioner
United States Board of Tax Appeals
In the circumstances herein it is held that the petitioner is not a dealer in personal property on the installment plan and, therefore, is not entitled to the benefit of the relief provision of section 705 of the Revenue Act of 1928.
1Opinion of the Court
*215OPINION.
Lansdon :
The petitioner’s major contention is that, in the circumstances as set out in our findings of fact, it properly changed its method of accounting for and reporting income from receipts on deferred payment contracts at January 1, 1924, and that thereafter *216it was entitled to report such income on tbe installment basis. If this contention is sound it follows that if it then comes within the provisions of section 105 (a) (2) of the Revenue Act of 1928 1 no deficiency can be determined against it in respect of the amount of $64,679.96 which was reported as taxable income in a prior…
2Cases cited3 opinions
- Elmer v. CommissionerUnited States Board of Tax Appeals · 1931
- Alworth-Washburn Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Chapman v. CommissionerUnited States Board of Tax Appeals · 1930
3Cited by2 opinions
- Iowa Guarantee Mortg. Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
- Motors Secs. Co. v. CommissionerUnited States Tax Court · 1952