Hallmark Cards, Inc. v. Commissioner

90 T.C. 26 (1988)

From our private database of 46,000+ case briefs, written and edited by humans—never with AI.

Hallmark Cards, Inc. v. Commissioner

United States Tax Court
90 T.C. 26 (1988)

SC

Facts

Hallmark Cards, Inc. (plaintiff) used the accrual method of accounting. Hallmark often shipped holiday-themed merchandise to its customers well in advance of holidays. However, merchants did not wish to receive Valentine’s Day merchandise before the end of the preceding calendar year due to the presence of Christmas merchandise already as well as yearend-inventory implications. As a result, Hallmark modified its sales and shipping documents: Hallmark shipped Valentine’s Day merchandise before the end of the preceding calendar year, but provided in the sales documents that title and risk of loss would not pass to the merchants until January 1. Consequently, Hallmark deferred reporting of its income related to the sales of the Valentine’s Day merchandise until the following year. The Internal Revenue Service (IRS) (defendant) assessed a deficiency for this practice, determining that Hallmark must report the income in the year in which it shipped the merchandise. Hallmark appealed

Rule of Law

Issue

Holding and Reasoning (Körner, 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 742,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead 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.

    Learn about our approachRead more about Quimbee

Here's why 742,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,000 briefs, keyed to 986 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.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 742,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,000 briefs - keyed to 986 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership