Rameau A. and Phyllis A. Johnson - Page 19

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            taxpayers in Hansen were accrual basis retail dealers who sold                            
            automobiles and house trailers on credit and then assigned the                            
            consumer installment paper to a finance company, guaranteeing the                         
            consumer's payment.  The finance company paid the dealer cash                             
            equal to the face amount of the installment paper less a                                  
            specified percentage that the finance company credited to a                               
            reserve account and withheld as collateral to secure the dealer's                         
            guaranty and other obligations to the finance company.                                    
            Periodically the finance company released to the dealer amounts                           
            in the reserve exceeding a stated percentage of the unpaid                                
            balances on installment paper purchased from the dealer.  On                              
            their tax returns the dealers currently included in income only                           
            the amounts paid to them by the finance company.  The dealers                             
            contended, first, that they had no right to receive amounts that                          
            they could not currently compel the finance company to pay them;                          
            second, their right to receive reserves did not become fixed so                           
            long as the amount that they would ultimately recover was subject                         
            to their contingent liabilities to the finance company.                                   
            Accordingly, the dealers argued, there was no basis for accrual                           
            of the reserves as income for the year in which the reserves were                         
            withheld and credited to the dealer's account.                                            
                  The Supreme Court rejected the dealers' first argument,                             
            stating that, under the accrual method, it was the time of                                
            acquisition of the fixed right to receive the reserves, not the                           





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