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RAY WOODS USED CARS, INC. v. COMMISSIONER

Docket No. 32062.

11 T.C.M. 983 (1952)

Ray Woods Used Cars, Inc. v. Commissioner.

United States Tax Court.

Entered September 30, 1952.

Attorney(s) appearing for the Case

Yale B. Griffis, Esq., 207 Empire State Bank Bldg., Dallas, Tex., for the petitioner. John W. Alexander, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

This proceeding involves a deficiency of $2,146.23 in income tax for the fiscal year ended May 31, 1949. The issue is whether the balance of $9,685.60 at the close of the taxable year in a reserve account set up by a finance company under an agreement with petitioner for the purchase of notes constitutes taxable income.

Findings of Fact

The stipulated facts are so found.

The...

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