Georgia School-Book Depository v. Commissioner

The Depository (plaintiff), an accrual-basis taxpayer, earned commissions brokering textbook purchases for both Georgia (a state government) and independent colleges, accruing college commissions when textbooks were purchased but deferring accrual of Georgia's commissions until actually paid, on the theory that recent underfunded free-textbook legislation meant there was no reasonable expectation Georgia would pay. The tax commissioner (defendant) argued the Georgia commissions should also be accrued at the time of purchase, and the Depository petitioned the Tax Court for redetermination.