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:
“Birth, and copulation, and death.
That’s all the facts when you come to brass tacks:
Birth, and copulation, and death.
I’ve been born, and once is enough.
You dont remember, but I remember,
Once is enough.”
—T.S. (Thomas Stearns)
“Science is built up with facts, as a house is with stones. But a collection of facts is no more a science than a heap of stones is a house.”
—Jules Henri Poincare (1854–1912)
“I went to the woods because I wished to live deliberately, to front only the essential facts of life, and see if I could not learn what it had to teach, and not, when I came to die, discover that I had not lived.... I wanted to live deep and suck out all the marrow of life, to live so sturdily and Spartan-like as to put to rout all that was not life, to cut a broad swath and shave close, to drive life into a corner, and reduce it to its lowest terms.”
—Henry David Thoreau (1817–1862)