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FEDERATED DEPARTMENT STORES, INC. v. COMMISSIONER

Docket No. 526-66.

51 T.C. 500 (1968)

FEDERATED DEPARTMENT STORES, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 30, 1968.

Attorney(s) appearing for the Case

Robert A. Schulman and Lyman G. Friedman, for the petitioner.

John J. Larkin, for the respondent.

OPINION

TIETJENS, Judge:

The Commissioner determined deficiencies in income tax for the taxable years ending February 2, 1963, and February 1, 1964, in the amounts of $302,761.83 and $1,940,544.91, respectively.

The only issues remaining for our decision are:

(1) Whether, at the time petitioner sold its accounts receivable to a bank, it must recognize as income, previously unrecognized service...

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