MORITZ v. COMMISSIONER

Docket No. 40488.

21 T.C. 622 (1954)

WALLACE A. MORITZ AND RUTH K. MORITZ, HUSBAND AND WIFE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated January 29, 1954.


Attorney(s) appearing for the Case

J. W. Bullion, Esq., and William E. Collins, Esq., for the petitioners.

J. Marvin Kelley, Esq., for the respondent.


This proceeding involves deficiencies in income tax of $14,845.51 for the year 1948 and of $1,665.84 for the year 1949 determined against Wallace A. Moritz (hereinafter referred to as the petitioner) and Ruth K. Moritz, his wife.

The issue to be determined is whether customers' deposits held by petitioner, an accrual basis taxpayer, at the end of the year, pending completion of photographic portraits and acceptance of them by the customers, were properly included...

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