- 16 - Artnell Co. v. Commissioner, 400 F.2d 981 (7th Cir. 1968), acq. 1968-2 C.B. 1, revg. and remanding 48 T.C. 411 (1967), involved facts very similar to those involved herein. Therein the Court of Appeals for the Seventh Circuit concluded that funds received by the Chicago White Sox, Inc. (White Sox) on advance ticket sales relating to major league baseball games to be played in a following year may appropriately be deferred and included in the White Sox’s income in the year when the games were to be played if that deferral would clearly reflect the White Sox’s income. Id. at 985. The Court of Appeals for the Seventh Circuit remanded the case to us for analysis of whether the White Sox’s deferral of reporting the funds as income until the year in which the games were played would clearly reflect income. Id. at 985-986. On remand in Artnell Co. v. Commissioner, T.C. Memo. 1970- 85, we concluded that the White Sox’s method of accounting for the funds clearly reflected income because deferral of the funds until the year in which the games were played more clearly than respondent’s method matched the income with the White Sox’s major expenses that were incurred in the year when the games were played. In subsequent opinions, we have stated that Artnell Co. will be limited to its facts. See Johnson v. Commissioner, 108 T.C. 448, 492 (1997), affd. in part, revd. in part, and remanded onPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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