Amend v. Commissioner
United States Tax Court
13 T.C. 178 (1959)
In 1944, J. D. Amend (plaintiff), a wheat farmer, entered into an arm’s-length contract to sell wheat to the Burrus Mill & Elevator Company (Burrus), with payment due in January 1945. Amend delivered the wheat to Burrus in August 1944. Burrus paid Amend for the wheat in January 1945 per the terms of their contract. Amend operated his business on the cash-basis method of accounting. Accordingly, Amend accounted for Burrus’s payment as gross income in 1945, the year Amend received the payment. The tax commissioner (commissioner) (defendant) issued a deficiency notice for the 1944 tax year, holding that Amend had constructive receipt of Burrus’s payment in 1944 and was obligated to pay taxes on the payment as income in that year. Amend petitioned the United States Tax Court for review of the commissioner’s deficiency notice.
Rule of Law
Holding and Reasoning (Black, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 174,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.