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Income Tax Keyed to Bankman
Georgia School-Book Depository v. Commissioner
Citation:
1 T.C. 463 (1943)Facts
Petitioner served as a book depository that brokered transactions of textbooks between the State of Georgia and various publishers. Petitioner executed contracts between the state and the publishers, held the books in its inventory until distribution to schools, and held in trust payments from the state to the publishers. Petitioner accrued a commission on the sale of books, which the state paid out of its Free Textbook Fund. In years 1938 and 1939, the fund was insufficient to pay for the books requested. Petitioner did not report income from the sales where the state failed to make a payment. The Commissioner of Internal Revenue asserted a deficiency, finding that the income had accrued to Petitioner even if the payments were not made.
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