Legal Opinion
W. T. Grant Company v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided August 22, 1973No. 770, Docket 72-2213PublishedCited by 10 opinions
1Opinion of the Court
J. JOSEPH SMITH, Circuit Judge:
The Commissioner of Internal Revenue appeals from a decision of the Tax Court, Charles R. Simpson, Judge, reviewed by the court, reported at 58 T.C. 290 (1972), holding that taxpayer’s sales under its Coupon Book Installment Plan qualify for installment method treatment under § 453 of the Internal Revenue Code of 1954. We find that the sales do not qualify under the Code 1 and the regulations 2 3 and reverse.
The facts are found in the Tax Court opinion and may be summarized as follows.
Grant’s provides its customers with three basic credit plans: (a) Special…
2Cases cited2 opinions
- Consolidated Dry Goods Company v. United StatesDistrict Court, D. Massachusetts · 1960
- W. T. Grant Co. v. CommissionerUnited States Tax Court · 1972
3Cited by10 opinions
- Mildred Ives v. W. T. Grant CompanyCourt of Appeals for the Second Circuit · 1975
- Little Redhouse, Brady Tah, on Behalf of Themselves and Others Similarly Situated v. Quality Ford Sales, Inc., a Utah Corporation, and Thomas E. ReddCourt of Appeals for the Tenth Circuit · 1975
- Fenton v. Citizens Savings AssociationDistrict Court, W.D. Missouri · 1975
- Gimbel Bros. v. United StatesUnited States Court of Claims · 1976
- Barton Beek and Dorothy M. Beek v. Commissioner of Internal Revenue, Gerald T. And Anne Sparling v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
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