Zaninovich v. Commissioner
United States Court of Appeals for the Ninth Circuit
616 F.2d 429 (1980)
In 1973, Martin and Vincent Zaninovich (plaintiffs) entered into a 20-year lease agreement for their farming business. The lease term ran from December 1 to November 30, with yearly rent due by December 20 of each year. The Zaninoviches used the cash-basis method of accounting, meaning that all of their expenses and gains were recognized at the time of actual payment or receipt for tax purposes. The Zaninoviches deducted the entire first year’s rental payment in their 1973 federal taxes. The commissioner of internal revenue (commissioner) (defendant) determined that the lease-payment deduction had to be prorated and that the Zaninoviches could only deduct the portion of rent allocable to December 1973. The Zaninoviches petitioned the tax court for a redetermination. The tax court sustained the commissioner’s decision. The Zaninoviches appealed to the United States Court of Appeals for the Ninth Circuit.
Rule of Law
Holding and Reasoning (Ferguson, 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 724,000 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
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 724,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 45,500 briefs, keyed to 983 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.