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Schlude v. Commissioner
(詳細は372 U.S. 128 (1963),〔(SCHLUDE V. COMMISSIONER, 372 U. S. 128 (1963) - US Supreme Court Cases from Justia & Oyez )〕 is a decision by the United States Supreme Court in which the Court held that, under the accrual method, taxpayers must include as income in a particular year advance payments by way of cash, negotiable notes, and contract installments falling due but remaining unpaid during that year. In doing so, the Court tossed aside the matching principle in favor of the earlier-of test.
==Facts==
The petitioners operated ballroom dancing studios. They kept their books and completed income tax returns on a fiscal year accrual basis. Dancing lessons were offered under either of two basic contracts. The cash plan contract required the student to pay the entire down payment in cash at the time the contract was executed with the balance due in installments thereafter. The deferred payment contract required only a portion of the down payment to be paid in cash, with the remainder of the down payment due in stated installments. The balance of the contract price was to be paid as designated in a negotiable note signed at the time the contract was executed.
The contracts included a specific number of lesson hours ranging from five to 1,200 hours. Some even provided for lifetime courses that entitled the student to two hours of lessons per month plus two parties a year for life. Although the contracts designated the period during which the lessons had to be taken, there was no schedule of specific dates.
The Commissioner included in gross income for the years in question advance payments by way of cash, negotiable notes, and contract installments falling due but remaining unpaid during that year. The Tax Court and the Court of Appeals upheld the Commissioner.
抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』
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