Quimbee logo with url
From our private database of 14,900+ case briefs...

Clifton Manufacturing Co. v. Commissioner

United States Court of Appeals for the Fourth Circuit
137 F.2d 290 (1943)


Facts

Hunter Manufacturing & Commission Company (Hunter) owed Clifton Manufacturing Company (Clifton) (plaintiff) almost $400,000. In 1933, Clifton believed that it would only receive about half of this amount due to Hunter’s recent receivership for liquidation, and doubted that it would recover interest on the past due receipts. However, in 1936, Hunter acquired enough money to pay Clifton the interest that had accrued from 1934 in 1937. Clifton used the accrual method of accounting and did not include the 1934 interest as gross income on its 1934, 1935, or 1937 tax returns. The commissioner of internal revenue (commissioner) (defendant) determined a deficiency in Clifton’s taxes for 1937. Clifton petitioned the United States Tax Court for a redetermination. The tax court ruled for the commissioner, holding that the 1934 interest was taxable in 1937. Clifton appealed.

Rule of Law

Issue

Holding and Reasoning (Soper, J.)

What to do next…

  1. 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.

  2. 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 284,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 14,900 briefs, keyed to 201 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.