Pacific Grape Products Co. v. Commissioner
United States Court of Appeals for the Ninth Circuit
219 F.2d 862 (1955)

- Written by Sean Carroll, JD
Facts
Pacific Grape Products Company (Pacific Grape) (plaintiff) canned its goods from July 1 to November 1 each year. Pacific Grape billed its customers on December 31 of each year for all their purchases that year, even if all the purchased goods had not yet been shipped. Pacific Grape accrued the revenue of all such sales in the year billed. Pacific Grape also incurred shipping expenses in the year billed even for goods not yet shipped. This was customary practice in the canning industry and was provided for in Pacific Grape’s contracts with its customers. The Internal Revenue Service (IRS) (defendant) determined that this accounting was improper and ruled that revenue from goods not shipped by the year’s end should accrue the following year. This determination resulted in tax deficiencies in certain years and excess profits in other years for Pacific Grape. The tax court upheld the IRS’s determination, finding that title in the sold goods did not pass to Pacific Grape’s customers until the goods were shipped. Pacific Grape appealed.
Rule of Law
Issue
Holding and Reasoning (Pope, J.)
What to do next…
Here's why 816,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 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.