Hagen Advertising Displays, Inc. v. Commissioner
United States Tax Court
Petitioner is in the business of manufacturing advertising signs. Many of its larger customers place "blanket orders" for several signs, with delivery to be made one by one over future months as directed by the customer. Some of these customers pay in advance for all of the signs ordered, and no restrictions are placed on petitioner's use of these customers' advances.
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Petitioner is in the business of manufacturing advertising signs. Many of its larger customers place "blanket orders" for several signs, with delivery to be made one by one over future months as directed by the customer. Some of these customers pay in advance for all of the signs ordered, and no restrictions are placed on petitioner's use of these customers' advances. Petitioner in computing its taxable income for the years here in issue and for prior years did not include the amounts of these advances in income until the year in which the signs for which the advance payments were made were…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies-in petitioner’s income tax for the calendar years 1960 and 1962, in the amounts of $25,033.04 and $16,119.60, respectively.
The issue for decision is whether amounts paid to petitioner by certain of its customers for products ordered from petitioner which were to be delivered by petitioner at a later date were properly excluded from taxable income by petitioner in each of the years here involved to the extent that the products ordered with respect to which the payments were made had not been shipped at the close of the taxable year.
FINDINGS OF…
Also in this document: Dissent.
2Cases cited11 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Brown v. HelveringSupreme Court of the United States · 1934
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- Schulde v. CommissionerSupreme Court of the United States · 1963
- Automobile Club of New York, Inc. v. CommissionerUnited States Tax Court · 1959
6 more not listed; retrieve them via the Exa API.
3Cited by38 opinions
- Bay State Gas Co. v. CommissionerUnited States Tax Court · 1980
- Hamilton Industries, Inc. v. CommissionerUnited States Tax Court · 1991
- Artnell Co. v. CommissionerUnited States Tax Court · 1967
- Hagen Advertising Displays, Inc., an Ohio Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1969
- S. Garber, Inc. v. CommissionerUnited States Tax Court · 1969
33 more not listed; retrieve them via the Exa API.