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GRAFF CHEVROLET COMPANY v. CAMPBELL

No. 21178.

343 F.2d 568 (1965)

GRAFF CHEVROLET COMPANY, Appellant, v. Ellis CAMPBELL, Jr., District Director of Internal Revenue, Appellee.

United States Court of Appeals Fifth Circuit.

March 29, 1965.

Attorney(s) appearing for the Case

Graham R. E. Koch, Akin, Vial, Hamilton, Koch & Tubb, Dallas, Tex., for appellant.

Carolyn R. Just, Dept. of Justice, Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Harry Baum, Alex A. Pandeleon, Attys., Dept. of Justice, Washington, D. C., H. Barefoot Sanders, U. S. Atty., Dallas, Tex., for appellee.

Before RIVES, BROWN and WISDOM, Circuit Judges.

WISDOM, Circuit Judge:

This case presents an apparent conflict between the adjustment provisions of section 481 of the Internal Revenue Code of 1954 and the statute of limitations,1 section 6501(a) of the Code.

The taxpayer, Graff Chevrolet Company, is a retail automobile dealer in Grand Prairie, Texas. Graff sells automobiles under a deferred payment plan, discounting the purchasers'...

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