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Artnell v. Commissioner
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Artnell v. Commissioner : ウィキペディア英語版
Artnell v. Commissioner

''Artnell Company v. Commissioner'', 400 F.2d 981 (7th Cir. 1968) is a decision by the 7th Circuit Court of Appeals, in which the court, distinguishing from the holding in ''Schlude v. Commissioner'', held that accrual method taxpayers are not required to include prepayments in gross income when there is certainty as to when performance would occur.
== 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.

抄文引用元・出典: フリー百科事典『 ウィキペディア(Wikipedia)
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