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Income Tax Keyed to Bankman
American Automobile Association v. United States
Citation:367 U.S. 687 (1961)
In the years 1952 to 1954, the American Automobile Association (the Association) reported as income only the portion of the total prepaid annual membership dues which ratably corresponded with the number of membership months covered by those dues and occurring within the same taxable calendar year. The balance of prepaid membership dues received was treated as deferred income reflecting an estimated future service expense to members. The Commissioner of Internal Revenue asserted a deficiency, contending that the Association should report as income all membership dues received in the year, rather than reporting only a prorated portion and deferring the rest.
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