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ARTNELL COMPANY v. C.I.R.

No. 16586.

400 F.2d 981 (1968)

ARTNELL COMPANY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Seventh Circuit.

September 19, 1968.

Attorney(s) appearing for the Case

William A. Cromartie, William P. Sutter, Thomas R. Mulroy, Harvey C. Flodin, Chicago, Ill., Samuel H. Horne, Washington, D. C., for petitioner; Hopkins, Sutter, Owen, Mulroy, Wentz & Davis, Chicago, Ill., of counsel.

Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, Harry Baum, Louis M. Kauder, Attys., Tax Division, Dept. of Justice, Washington, D. C., for respondent.

Before KILEY, SWYGERT and FAIRCHILD, Circuit Judges.

FAIRCHILD, Circuit Judge.

The tax court upheld the commissioner's determination of deficiencies,1 and Artnell Company, transferee taxpayer, seeks review. The main question is whether prepayments for services (proceeds of advance sales of tickets for baseball games and revenues for related future services) must be treated as income when received or whether such treatment could be deferred by the accrual basis taxpayer until the games were...

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