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HAGEN ADVERTISING DISPLAYS, INC. v. C. I. R.

No. 18015.

407 F.2d 1105 (1969)

HAGEN ADVERTISING DISPLAYS, INC., an Ohio corporation, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

March 3, 1969.

Attorney(s) appearing for the Case

Robert O. Leming, Cincinnati, Ohio, for petitioner; Rolf, Dolle, Rueger, Mongan & Leming, Cincinnati, Ohio, on brief.

Louis M. Kauder, Atty., Department of Justice, Washington, D. C., for respondent; Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, Harry Baum, Jonathan S. Cohen, Attys., Dept. of Justice, Washington, D. C., on brief.

Before EDWARDS, McCREE, and COMBS, Circuit Judges.

McCREE, Circuit Judge.

This is a petition to review a decision of the Tax Court upholding the Commissioner's determination that taxpayer must include advance payments from its customers in its gross income in the year of receipt.

Hagen Advertising Displays, Inc., petitioner-taxpayer, is a manufacturer of advertising signs with its principal office in Cincinnati, Ohio. Many of petitioner's customers are engaged in establishing new dealerships throughout the...

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