Curran Realty Co. v. Commissioner
United States Tax Court
1. Income -- Accrual Basis -- Reversing Entries. -- Taxpayer properly reported accrued rent as shown on corporate books after reversing entries had eliminated amounts which were collected but later refunded. 2. Deductions -- Accrual Basis -- State Tax on Income -- Increases Due to Deficiency Determination. -- Additional deduction for state excise tax proper where adjustments made by Commissioner increasing net income were proper and uncontested but not where they were…
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1. Income -- Accrual Basis -- Reversing Entries. -- Taxpayer properly reported accrued rent as shown on corporate books after reversing entries had eliminated amounts which were collected but later refunded. 2. Deductions -- Accrual Basis -- State Tax on Income -- Increases Due to Deficiency Determination. -- Additional deduction for state excise tax proper where adjustments made by Commissioner increasing net income were proper and uncontested but not where they were contested.
1Opinion of the Court
OPINION.
Murdock, Judge:
Patrick J. Curran and his wife owned all of the stock of the petitioner and of its lessee. Curran was the president of both corporations. He learned in the latter part of 1946 that the revenue agent would not allow a deduction to Liberty for rent in excess of $1,250 a month, which the agent considered reasonable for the premises. Curran agreed to the adjustment made by the agent, determined upon behalf of the lessor to adjust the liability for rent to conform, and caused adjusting entries to be made on the books of the petitioner, as well as on the books of Liberty,…
2Cases cited4 opinions
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Taylor Instrument Cos. v. CommissionerUnited States Tax Court · 1950
- Clark v. CommissionerUnited States Tax Court · 1948
- Simon v. CommissionerUnited States Tax Court · 1948
3Cited by12 opinions
- Howard B. Quinn and Charlotte J. Quinn v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1975
- United States v. MerrillCourt of Appeals for the Ninth Circuit · 1954
- Bishop v. CommissionerUnited States Tax Court · 1956
- Gaddy v. CommissionerUnited States Tax Court · 1962
- Frelbro Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1963
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