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
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“Now, what I want is, Facts. Teach these boys and girls nothing but Facts. Facts alone are wanted in life. Plant nothing else, and root out everything else. You can only form the minds of reasoning animals upon Facts: nothing else will ever be of any service to them. This is the principle on which I bring up my own children, and this is the principle on which I bring up these children. Stick to Facts, sir!”
—Charles Dickens (1812–1870)