City Gas Co. v. Commissioner
United States Tax Court
Petitioners are gas utility companies. Before service was commenced, petitioners required each customer to make a cash deposit to secure payment of all bills rendered to the customer. When service was terminated the deposit was typically credited against charges for gas consumed and other items in the customer's final bill. Held: The deposits are better characterized as prepayments of income items than as security for non-income-producing covenants.
Read the full summary
Petitioners are gas utility companies. Before service was commenced, petitioners required each customer to make a cash deposit to secure payment of all bills rendered to the customer. When service was terminated the deposit was typically credited against charges for gas consumed and other items in the customer's final bill. Held: The deposits are better characterized as prepayments of income items than as security for non-income-producing covenants. Therefore, the deposits constituted income to petitioners. Held: The deposits constituted substantial advance payments for inventoriable goods…
1Opinion of the Court
CITY GAS COMPANY OF FLORIDA, et al., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
City Gas Co. v. Commissioner
Docket Nos. 8808-73, 8807-73, 8809-73.
United States Tax Court
T.C. Memo 1984-44; 1984 Tax Ct. Memo LEXIS 629; 47 T.C.M. (CCH) 971; T.C.M. (RIA) 84044;
January 26, 1984.
Petitioners are gas utility companies. Before service was commenced, petitioners required each customer to make a cash deposit to secure payment of all bills rendered to the customer. When service was terminated the deposit was typically credited against charges for gas consumed and other items in the…
2Cases cited18 opinions
- Memphis Light, Gas & Water Division v. CraftSupreme Court of the United States · 1978
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
- Commissioner v. First Security Bank of Utah, N. A.Supreme Court of the United States · 1972
- Goodell v. KochSupreme Court of the United States · 1930
13 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Oak Industries, Inc. v. CommissionerUnited States Tax Court · 1991
- Indianapolis Power & Light Co. v. CommissionerUnited States Tax Court · 1987
- Indianapolis Power & Light Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1988
- Gas Light Co. v. CommissionerUnited States Tax Court · 1986
- Indianapolis Power & Light Co. v. CommissionerUnited States Tax Court · 1987
1 more not listed; retrieve them via the Exa API.