Kimbrell's Home Furnishings, Inc. v. Commissioner
United States Tax Court
Petitioner, a corporation engaged in the sale of furniture at retail, computed its normal tax net income on the installment basis. It computed its excess profits income on the accrual basis, pursuant to section 736 (a) of the Internal Revenue Code.
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Petitioner, a corporation engaged in the sale of furniture at retail, computed its normal tax net income on the installment basis. It computed its excess profits income on the accrual basis, pursuant to section 736 (a) of the Internal Revenue Code. Held, that petitioner's reserve for unrealized profits on installment sales as of the beginning of the taxable year is not includible in equity invested capital as accumulated earnings and profits within section 718 (a) (4) of the Internal Revenue Code.
1Opinion of the Court
OPINION.
Hill, Judge:
Having come into existence after January 1, 1940, petitioner was required, in determining its excess profits tax liability for the fiscal year ended August 31,1943, to compute its excess profits credit under section 714 of the Internal Revenue Code. This computation required an ascertainment of its equity invested capital, which, by section 718 (a), is defined as including the “accumulated earnings and profits as of the beginning of such taxable year.1 Petitioner contends on two separate grounds that such accumulated earnings and profits include its reserve as of August…
2Cases cited2 opinions
- Wheeler v. CommissionerUnited States Tax Court · 1943
- Federal Union Ins. Co. v. CommissionerUnited States Tax Court · 1945
3Cited by18 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- J. L. Goodman Furniture Co. v. CommissionerUnited States Tax Court · 1948
- Basalt Rock Co. v. CommissionerUnited States Tax Court · 1948
- Hart Furniture Co. v. CommissionerUnited States Tax Court · 1949
- South Texas Lumber Co. v. CommissionerCourt of Appeals for the Fifth Circuit · 1947
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