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Income Tax Keyed to Bankman
Amend v. Commissioner
Citation:13 T.C. 178 (1949), acq., 1950-1 C.B. 1
In 1944, Petitioner, a farmer using cash basis accounting, contracted to sell wheat crops to Burrus, a grain dealer. The agreement called for Petitioner to transfer the crops in August 1944 but Burrus would not pay until January 1945. Petitioner received payment in January and reported the income on his 1945 tax return. The Commissioner of Internal Revenue asserted a deficiency, finding that Petitioner had constructive receipt of payment, and thus taxable income, back when the agreement was made and the crops transferred in 1944.
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