United States Tax Court July 17, 1964, Docket No. 80278 (Luhring Motor Co. v. Commissioner)

Fishee, Judge:

Respondent determined deficiencies in petitioner’s income tax for the year 1955 in the amount of $119,152.02.

The issues presented for our consideration are:

Whether the entire amount of finance charges provided for in conditional sales contracts received by petitioner during 1955 constitutes income to petitioner as of the time the contracts were entered into, or whether the