Legal Opinion

Copy Data, Inc. v. Commissioner

United States Tax Court

Decided July 18, 1988No. Docket No. 44846-86Published

Petitioner was engaged in the business of sale and service of photocopying equipment. On its tax returns, petitioner deducted "sales exposure expense" relating to warranty obligations to its customers. The amount deducted each year was a composite of an adjustment to an established reserve account and actual expenses for the year. Petitioner acquiesced in respondent's disallowance of the method of determining expense.

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Petitioner was engaged in the business of sale and service of photocopying equipment. On its tax returns, petitioner deducted "sales exposure expense" relating to warranty obligations to its customers. The amount deducted each year was a composite of an adjustment to an established reserve account and actual expenses for the year. Petitioner acquiesced in respondent's disallowance of the method of determining expense. Held, discontinuance of petitioner's practice constituted a "change in method of accounting" within the meaning of sec. 481, I.R.C. 1954, as amended, and the remaining balance…

1Opinion of the Court

Copy Data, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Copy Data, Inc. v. Commissioner

Docket No. 44846-86

United States Tax Court

91 T.C. 26; 1988 U.S. Tax Ct. LEXIS 88; 91 T.C. No. 3;

July 18, 1988. July 18, 1988, Filed

Decision will be entered for the respondent.

Petitioner was engaged in the business of sale and service of photocopying equipment. On its tax returns, petitioner deducted "sales exposure expense" relating to warranty obligations to its customers. The amount deducted each year was a composite of an adjustment to an established reserve account and actual expenses…

2Cases cited8 opinions

  1. Knight-Ridder Newspapers, Inc. v. United StatesCourt of Appeals for the Eleventh Circuit · 1984
  2. Graff Chevrolet Company v. Ellis Campbell, Jr., District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1965
  3. Schuster's Express, Inc. v. CommissionerUnited States Tax Court · 1976
  4. Primo Pants Co. v. CommissionerUnited States Tax Court · 1982
  5. Peoples Bank & Trust Co. v. CommissionerUnited States Tax Court · 1968

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