T.C. Memo. 2003-340 UNITED STATES TAX COURT PERRY FUNERAL HOME, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14722-02. Filed December 16, 2003. P is a funeral home organized and operating in Massachusetts. During the years in issue, P entered into preneed funeral contracts and received payments in advance of death for goods and services to be provided later at the contract beneficiary’s death. These payments were refundable at the contract purchaser’s request, pursuant to State law, at any time until the goods and services were furnished. P, an accrual basis taxpayer, included these payments in income not in the year of receipt but in the year in which the goods and services were provided. Held: Payments received by P under its preneed funeral contracts are includable in gross income only upon the provision of the subject goods and services. Held, further, P is liable for the sec. 6662, I.R.C., accuracy-related penalty with respect to items conceded by P, apart from the preneed accounting issue.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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