Ryan v. Commissioner
United States Tax Court
Petitioners, accrual basis taxpayers, voluntarily changed their method of treatment of dealer reserve income for their taxable year ending December 31, 1957. Held: Petitioners' change in treatment of dealer reserve income was a change in method of accounting within the meaning of section 481, I.R.C. 1954. Section 481 is applicable and permits respondent to include in petitioners' income for the year 1957 the balance in petitioners' dealer reserve accounts as of December 31,…
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Petitioners, accrual basis taxpayers, voluntarily changed their method of treatment of dealer reserve income for their taxable year ending December 31, 1957. Held: Petitioners' change in treatment of dealer reserve income was a change in method of accounting within the meaning of section 481, I.R.C. 1954. Section 481 is applicable and permits respondent to include in petitioners' income for the year 1957 the balance in petitioners' dealer reserve accounts as of December 31, 1957, even though a part of those balances were credited to the accounts prior to January 1, 1957. Held, further, the…
1Opinion of the Court
DeeNNEN, Judge:
Respondent determined deficiencies in petitioners’ income tax for the years 1956 and 1957 in the amounts of $17,584.80 and $34,262.88, respectively. By stipulation petitioners conceded all adjustments in the notice of deficiency except adjustments with respect to dealer reserve income.
The only issues remaining for decision are (1) whether petitioners’ change in method of reporting dealer reserve income for their taxable year 1957 constituted a change in method of accounting within the meaning of section 481,1.R.C. 1954,1 so as to make that section applicable, and (2) if so,…
2Cases cited17 opinions
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Commissioner v. HansenSupreme Court of the United States · 1959
- Lilly v. CommissionerSupreme Court of the United States · 1952
- Commissioner of Internal Revenue v. Mnookin's EstateCourt of Appeals for the Eighth Circuit · 1950
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3Cited by14 opinions
- Graff Chevrolet Company v. Ellis Campbell, Jr., District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1965
- H. F. Campbell Co. v. CommissionerUnited States Tax Court · 1969
- Shepherd Constr. Co. v. CommissionerUnited States Tax Court · 1969
- Western Casualty & Surety Co. v. CommissionerUnited States Tax Court · 1976
- W. S. Badcock Corp. v. CommissionerUnited States Tax Court · 1972
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