The taxpayer was in the business of rebuiliding Ford engines, which it sold to Ford dealers. In order to secure a regular supply of rebuildable engines, when it sold an engine to a dealer, it required that the dealer provide it with a large deposti, which it would repay once the dealer provided it with another rebuildable engine. The probabilities were 96% that a deposit would be returned to a dealer in the near future.
Although the deposits received by the taxpayer did not constitute a trust fund in its hands, they nonetheless were not ordinary trading receipts, and a deposit was not to be included in the computation of its profit from its business until the taxpayer ceased to be under a liability to return the deposit to the dealer.