Legal Opinion
Citizens Hotel Co. v. Commissioner
Court of Appeals for the Fifth Circuit
Decided April 6, 1942No. 10109PublishedCited by 12 opinions
1Opinion of the Court
SIBLEY, Circuit Judge.
The question is whether in income tax returns on an accrual basis, annual State, County and City taxes on property in Texas used in making the income must be treated as accruing in a lump sum on January first, or may be prorated when the return is for a part of the year.
The taxpayer, Citizens Hotel Company, had a fiscal year ending March 31. With the Commissioner’s consent in the early part of 1937 the fiscal year was changed so as to end January 31. In the fall of 1937 with the Commissioner’s consent change was made to a calendar year to begin January 1, 1938. Under…
2Cases cited4 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- American National Co. v. United StatesSupreme Court of the United States · 1927
- Carondelet Bldg. Co. v. FontenotCourt of Appeals for the Fifth Circuit · 1940
- Helvering v. S. E. & M. E. Bernheimer Co.Court of Appeals for the Second Circuit · 1941
3Cited by12 opinions
- Aron v. GillmanNew York Court of Appeals · 1955
- Wolan v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1950
- Broida, Stone & Thomas, Inc. v. United StatesDistrict Court, N.D. West Virginia · 1962
- COMMISSIONER OF INT. REVENUE v. Schock, Gusmer & Co.Court of Appeals for the Third Circuit · 1943
- Tennessee Life Insurance Company v. R. L. Phinney, District Director of Internal Revenue at Austin, TexasCourt of Appeals for the Fifth Circuit · 1960
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