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TECUMSEH CORRUGATED BOX CO. v. C.I.R.

No. 90-1814.

932 F.2d 526 (1991)

TECUMSEH CORRUGATED BOX COMPANY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided May 7, 1991.

Attorney(s) appearing for the Case

Stephen M. Feldman, Michael P. Witzke, Sheldon A. Fealk (argued), Couzens, Lansky, Fealk, Ellis, Roeder & Lazar, Farmington Hills, Mich., for petitioner-appellant.

Abraham N.M. Shashy, Jr., Chief Counsel, Internal Revenue Service, Office of Chief Counsel, Washington, D.C., Gary R. Allen, Acting Chief, Richard Farber, Bruce R. Ellisen, Charles Bricken (argued), U.S. Dept. of Justice, Appellate Section Tax Div., Washington, D.C., for respondent-appellee.

Before MERRITT, Chief Judge, GUY and NORRIS, Circuit Judges.

RALPH B. GUY, Jr., Circuit Judge.

Petitioner, Tecumseh Corrugated Box Company (petitioner, taxpayer, or Tecumseh), appeals from a Tax Court decision finding in favor of respondent, Commissioner of Internal Revenue (respondent or Commissioner). The Tax Court held that petitioner could not use the installment method to account for capital gains resulting from the sale of its properties. 94 T.C. 360.

Petitioner argues that the...

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