Legal Opinion

Schuster's Express, Inc. v. Commissioner

United States Tax Court

Decided June 24, 1976No. Docket No. 7420-73Published

Petitioner, an accrual basis taxpayer, maintained some of its expense accounts on an estimated basis for monthly reporting purposes. Such estimates were also used by petitioner in computing expense deductions claimed on its Federal income tax returns for the taxable years ended June 30, 1966, through June 30, 1970. The balance of a reserve account was increased each year by the amount by which the estimates exceeded actual cash expenditures for such items during the year.

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Petitioner, an accrual basis taxpayer, maintained some of its expense accounts on an estimated basis for monthly reporting purposes. Such estimates were also used by petitioner in computing expense deductions claimed on its Federal income tax returns for the taxable years ended June 30, 1966, through June 30, 1970. The balance of a reserve account was increased each year by the amount by which the estimates exceeded actual cash expenditures for such items during the year. Respondent determined that petitioner's accounting practice did not clearly reflect income and disallowed the deductions…

1Opinion of the Court

Schuster's Express, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Schuster's Express, Inc. v. Commissioner

Docket No. 7420-73

United States Tax Court

66 T.C. 588; 1976 U.S. Tax Ct. LEXIS 84;

June 24, 1976, Filed

Decision will be entered under Rule 155.

Petitioner, an accrual basis taxpayer, maintained some of its expense accounts on an estimated basis for monthly reporting purposes. Such estimates were also used by petitioner in computing expense deductions claimed on its Federal income tax returns for the taxable years ended June 30, 1966, through June 30, 1970. The balance of a…

2Cases cited18 opinions

  1. Estate of Horvath v. CommissionerUnited States Tax Court · 1973
  2. United States v. CattoSupreme Court of the United States · 1966
  3. Commissioner of Internal Revenue v. Chelsea Products, IncCourt of Appeals for the Third Circuit · 1952
  4. Rubin v. CommissionerUnited States Tax Court · 1971
  5. Graff Chevrolet Company v. Ellis Campbell, Jr., District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1965

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