RACMP Enters. v. Commissioner
United States Tax Court
P is a construction contractor that enters into contracts to construct, place, and finish concrete foundations, driveways, and walkways for real property developers. P uses the cash method to recognize income and to expense the cost of concrete and other materials. R determined that the material P uses in providing service to its clients is "merchandise" under sec. 1.471-1, Income Tax Regs., and that P must report its income on the accrual method of accounting.
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P is a construction contractor that enters into contracts to construct, place, and finish concrete foundations, driveways, and walkways for real property developers. P uses the cash method to recognize income and to expense the cost of concrete and other materials. R determined that the material P uses in providing service to its clients is "merchandise" under sec. 1.471-1, Income Tax Regs., and that P must report its income on the accrual method of accounting. HELD: P's contract to provide labor and material to a real property developer is a contract to provide service, and the material is…
1Opinion of the Court
RACMP ENTERPRISES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
RACMP Enters. v. Commissioner
No. 23954-97
United States Tax Court
114 T.C. 211; 2000 U.S. Tax Ct. LEXIS 21; 114 T.C. No. 16;
March 30, 2000, Filed
Decision will be entered for Petitioner.
P is a construction contractor that enters into contracts
to construct, place, and finish concrete foundations, driveways,
and walkways for real property developers. P uses the cash
method to recognize income and to expense the cost of concrete
and other materials. R determined that the material P uses in
providing service to its…
Also in this document: Dissent · Gerber; Dissent · Halpern.
2Cases cited61 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Commissioner v. HansenSupreme Court of the United States · 1959
- Aced v. Hobbs-Sesack Plumbing Co.California Supreme Court · 1961
- McCaughn v. LudingtonSupreme Court of the United States · 1925
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