Husch Bros., Inc. v. Commissioner

*1058OPINION.

TRAmmell :

The parties have presented only one question for our decision and that is whether the amount of $8,982.06 was income *1059in that year or in the fiscal year 1923 when the petitioner claims the amount was actually realized as income upon the termination of its liability as bailee or warehouseman. In other words the question is whether the amount was taxable income in the fiscal year 1920 or 1923. No other issue is presented or argued. The insurance policies taken out by petitioner, while having a clause covering the merchandise of customers in the hands of petitioner, did not show…