Jamaica Water Supply Co. v. Commissioner of Internal Revenue‪.‬

The controversy is whether the sum of $575,000.00 in principal and interest which the petitioner was paid on July 25, 1934 by the City of New York under an agreement made in December 1933 to settle its suit against the City to recover the fair value of hydrant service it had furnished during the years 1923 to 1928, inclusive, was properly included by the Commissioner in the petitioners gross income for its fiscal year ended June 30, 1934. The Board of Tax Appeals held that it was and this petition was brought to review that decision. The petitioner contends that the payment should have been allocated to the years in which the money was earned or, in the alternative, should have been treated as income for its fiscal year 1935 in which it was actually received.