W. T. Grant Co. v. Commissioner
United States Tax Court
The petitioner maintains a coupon book installment plan under which a book of coupons is paid for in installments, and the coupons may be exchanged for merchandise at any of the petitioner's stores. During 1964 and 1965, the petitioner also maintained plans under which certain employees were given the opportunity to purchase shares of the petitioner's stock and to pay for it over a 10-year period. Such stock was not to be issued until it was fully paid for.
Read the full summary
The petitioner maintains a coupon book installment plan under which a book of coupons is paid for in installments, and the coupons may be exchanged for merchandise at any of the petitioner's stores. During 1964 and 1965, the petitioner also maintained plans under which certain employees were given the opportunity to purchase shares of the petitioner's stock and to pay for it over a 10-year period. Such stock was not to be issued until it was fully paid for. Before the stock was issued, the petitioner quarterly credited each participating employee's purchase account with certain net dividend…
1Opinion of the Court
Simpson, Judge:
The respondent determined deficiencies in the petitioner’s income tax for the taxable years ended January 31, 1964 and 1965, in the respective amounts of $4,594,199 and $5,376,267. Since the respondent has conceded one issue raised in the pleadings, the remaining issues for decision are: (1) Whether the petitioner’s sales under its “Coupon Book Installment Plan” qualify for installment method treatment under section 453 of the Internal Itevenue Code of 1954,1 and (2) whether the petitioner is entitled to deduct certain amounts credited to the accounts of its employees under its…
2Cases cited13 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Burnet v. S. & L. Building Corp.Supreme Court of the United States · 1933
- Bingham v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1939
- Prendergast v. CommissionerUnited States Board of Tax Appeals · 1931
- Blum's, Inc. v. CommissionerUnited States Board of Tax Appeals · 1927
8 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Mildred Ives v. W. T. Grant CompanyCourt of Appeals for the Second Circuit · 1975
- W. T. Grant Company v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1973
- W. T. Grant Co. v. CommissionerUnited States Tax Court · 1972