H. F. Campbell Co. v. Commissioner
United States Tax Court
From 1954 through 1961 petitioner used a type of completed-contract method, which employed the following criteria to determine when gross income from its long-term contracts was to be included in computing its taxable income: (1) Physical completion, (2) customer acceptance, (3) recordation of all costs, and (4) computation of the final bill. After an audit of its returns for 1960 and 1961 was begun, petitioner reported its income for 1962 using only the first two criteria.
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From 1954 through 1961 petitioner used a type of completed-contract method, which employed the following criteria to determine when gross income from its long-term contracts was to be included in computing its taxable income: (1) Physical completion, (2) customer acceptance, (3) recordation of all costs, and (4) computation of the final bill. After an audit of its returns for 1960 and 1961 was begun, petitioner reported its income for 1962 using only the first two criteria. Held, utilization of only the two criteria in 1962 constituted a change in petitioner's method of accounting, for which…
1Opinion of the Court
Feati-ieRston, Judge:
Respondent determined deficiencies in petitioner’s income tax as follows:
Year Income taco
1960 _$42,808.49
1961 _ 39,344.47
1962 _ 4,421.56
Certain issues have been settled by the parties. The principal issue remaining for decision is whether for 1962 a change was made in petitioner’s method of accounting within the meaning of section 481(a).1 If the answer to this question is affirmative we must then decide whether the change was initiated by petitioner and whether adjustments necessary solely by reason of the change are required under section 481 to prevent amounts from…
2Cases cited26 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Fruehauf Trailer Co. v. CommissionerUnited States Tax Court · 1964
- Pursell v. CommissionerUnited States Tax Court · 1962
- Commissioner of Internal Revenue v. DwyerCourt of Appeals for the Second Circuit · 1953
- Commissioner of Internal Revenue v. O. Liquidating CorporationCourt of Appeals for the Third Circuit · 1961
21 more not listed; retrieve them via the Exa API.
3Cited by38 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Wayne Bolt & Nut Co. v. CommissionerUnited States Tax Court · 1989
- FPL Group, Inc. v. CommissionerUnited States Tax Court · 2000
- Peninsula Steel Products & Equipment Co. v. CommissionerUnited States Tax Court · 1982
- Sara Lee Corp. & Subsidiaries v. United StatesUnited States Court of Federal Claims · 1993
33 more not listed; retrieve them via the Exa API.