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:
“Each truth that a writer acquires is a lantern, which he turns full on what facts and thoughts lay already in his mind, and behold, all the mats and rubbish which had littered his garret become precious. Every trivial fact in his private biography becomes an illustration of this new principle, revisits the day, and delights all men by its piquancy and new charm.”
—Ralph Waldo Emerson (1803–1882)
“Experiences in order to be educative must lead out into an expanding world of subject matter, a subject matter of facts or information and of ideas. This condition is satisfied only as the educator views teaching and learning as a continuous process of reconstruction of experience.”
—John Dewey (1859–1952)
“Neither moral relations nor the moral law can swing in vacuo. Their only habitat can be a mind which feels them; and no world composed of merely physical facts can possibly be a world to which ethical propositions apply.”
—William James (1842–1910)