HINSHAW'S INC. v. COMMISSIONER

Docket No. 1523-92.

68 T.C.M. 108 (1994)

T.C. Memo. 1994-327

Hinshaw's, Inc. v. Commissioner.

United States Tax Court.

Filed July 18, 1994.


Attorney(s) appearing for the Case

William Graham, for the petitioner. Terri A. Merriam and Laurel M. Robinson, for the respondent.


Memorandum Findings of Fact and Opinion

PARR, Judge:

Respondent determined deficiencies in petitioner's Federal income tax for 1988 and 1989 of $166,347.19 and $173,821.63 respectively.

The issues for decision are: (1) Whether all amounts collected by petitioner from customers for long-term vehicle service contracts (hereinafter VSC) must be included in gross income in the year of receipt under section 61.1 We hold that...

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