Campbell v. Commissioner

United States Board of Tax Appeals

Decided February 4, 1927

United States Board of Tax Appeals · decided 1927-02-04

Cited by 4 later decisions — most recently September 1942

1 federal appellate ·

Key passage — most relied on by later courts

“Petitioner consistently kept bis books and rendered bis returns upon tbe accrual basis. Wlien tbe directors of tbe Glamorgan Pipe & Foundry Co., of wbieb be was chairman, by appropriate resolution in December, 1922, declared tbe cash dividend, petitioner accrued bis proportion thereof upon bis books as income and reported the same in bis income-tax return for tbe year 1922. It is not claimed by tbe Commissioner and there is nothing to indicate that tbe method of accounting employed by petitioner in keeping bis books of account, in accordance with which bis return was filed, did not clearly reflect bis income. We therefore approve tbe petitioner’s treatment of tbe dividend as income in 1922.”

quoted by 1 later decision, including Bingham v. Commissioner

Good law ✅— No negative treatment on recordhow we know

Decided 1927-02-04

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¶1 *61OPINION.

Littleton :

¶2Petitioner consistently kept his books and rendered his returns upon the accrual basis. When the directors of the Glamorgan Pipe & Foundry Co., of which he was chairman, by appropriate resolution in December, 1922, declared the cash dividend, petitioner accrued his proportion thereof upon his books as income and reported the same in his income-tax return- for the year 1922. It is not claimed by the Commissioner and there is nothing to indicate that the method of accounting employed by petitioner in keeping his books of account, in accordance with which his return was filed, did not clearly reflect his income. We therefore approve the petitioner’s treatment of the dividend as income in 1922.

¶3Judgment will be entered on 15 days' notice, wader Rule 50.