J. J. Little & Ives Co. v. Commissioner
United States Tax Court
Held: (1) Contracts in the taxable years between petitioner and merchants relating to books published by petitioner were contracts of sale, known as "sale or return" contracts, and not consignment contracts. (2) Sec. 1.451-3, Income Tax Regulations, permitting reporting income from construction contracts in year of completion of contract does not apply to petitioner; petitioner cannot report income from sales of books under a completed contract, or completed deal, method.
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Held: (1) Contracts in the taxable years between petitioner and merchants relating to books published by petitioner were contracts of sale, known as "sale or return" contracts, and not consignment contracts. (2) Sec. 1.451-3, Income Tax Regulations, permitting reporting income from construction contracts in year of completion of contract does not apply to petitioner; petitioner cannot report income from sales of books under a completed contract, or completed deal, method. (3) No provision of the 1954 Code, or the regulations, permits petitioner to deduct an amount for a reserve for…
1Opinion of the Court
J. J. Little & Ives Co., Inc. v. Commissioner.
J. J. Little & Ives Co. v. Commissioner
Docket No. 90574.
United States Tax Court
T.C. Memo 1966-68; 1966 Tax Ct. Memo LEXIS 214; 25 T.C.M. (CCH) 372; T.C.M. (RIA) 66068;
March 31, 1966
Held: (1) Contracts in the taxable years between petitioner and merchants relating to books published by petitioner were contracts of sale, known as "sale or return" contracts, and not consignment contracts. (2) Sec. 1.451-3, Income Tax Regulations, permitting reporting income from construction contracts in year of completion of contract does not apply to petitioner;…
2Cases cited16 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Brown v. HelveringSupreme Court of the United States · 1934
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
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3Cited by2 opinions
- Ertegun v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Ahmet Ertegun and Ioana Ertegun v. Commissioner of Internal Revenue, Gerald Wexler and Shirley Wexler v. Commissioner of Internal Revenue, Nesuhi Ertegun and Belkis Ertegun v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976