Georgia School-Book Depository v. Commissioner
United States Tax Court
1 T.C. 463 (1943)
The Georgia School-Book Depository (Depository) (plaintiff) was a broker that earned commissions by purchasing textbooks on behalf of the State of Georgia (Georgia) for public schools, as well as a few independent colleges. Depository paid its taxes on the accrual accounting basis. Depository accrued its commissions from the colleges at the time the textbooks were purchased. However, Depository did not accrue its commissions from Georgia until the commissions were paid, taking the position that those commissions were not earned until paid. The federal tax commissioner (defendant) sought to tax Depository on the commissions earned from Georgia in the tax year that the textbooks were purchased. Depository asserted that because there was no reasonable expectation that Georgia would pay the commissions, Depository appropriately deferred accruing commissions from Georgia until Depository received payment. Depository noted that Georgia recently had enacted legislation to provide free textbooks for public schools without allocating adequate public funding. Depository petitioned the United States Tax Court for a redetermination, arguing that Depository was entitled to accrue commissions from Georgia at the time the commissions were received.
Rule of Law
Holding and Reasoning (Kern, 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 177,000 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.