Johnson v. Commissioner of Internal Revenue

The principal question on this petition to review a decision of the Tax Court is whether amounts withheld by finance companies purchasing notes from taxpayer, an accrual basis trailer dealer, and set up and credited to his "dealers reserve" account on the companies books as reserves against possible losses, pursuant to agreements between the companies and taxpayer, should be considered taxable income to him (a) in the years in which they are so credited, or (b) in the years in which they become payable to him under the terms of the agreements.