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American Automobile Association v. United States

United States Supreme Court

367 U.S. 687 (1961)

Relevant factsFree

AAA (plaintiff) collected annual prepaid membership dues but, using accrual accounting, reported only a pro-rata portion of each member's dues as income in the year received, deferring the rest to offset anticipated future service costs; the Commissioner taxed the dues as fully earned in the year received, following a prior Supreme Court decision rejecting a similar automobile club's accrual method as artificial.

IssueFree

Whether, under federal tax law, an accrual-basis taxpayer must recognize prepaid membership dues as fully earned income when received.

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