Facts
The petitioner, an accrual method taxpayer, operated the Chicago White Sox professional baseball franchise using a fiscal year for federal income tax purposes. During the 1962 taxable year, the club sold single and season tickets to games to be played during the 1963 taxable year. The petitioner failed to report income from the sales on its 1962 return and instead reported the receipts as income in 1963.
The petitioner's decision to include income from its ticket sales in 1963, rather than 1962, was part of their practice of reporting income from ticket sales as the corresponding games were played.
The Commissioner argued that, in light of Schlude v. Commissioner, the income should have been reported in the year in which the payment was received, the 1962 taxable year.
Read more about this topic: Artnell V. Commissioner
Famous quotes containing the word facts:
“Live in contact with dreams and you will get something of their charm: live in contact with facts and you will get something of their brutality. I wish I could find a country to live in where the facts were not brutal and the dreams not real.”
—George Bernard Shaw (1856–1950)
“Still, it will sometimes strike a scientific man that the philosophers have been less intent on finding out what the facts are, than on inquiring what belief is most in harmony with their system.”
—Charles Sanders Peirce (1839–1914)
“Theories that go counter to the facts of human nature are foredoomed.”
—Edith Hamilton (1867–1963)