Amity Leather Products Co. v. Commissioner
United States Tax Court
During the years in issue, P was a domestic manufacturer of personal leather goods. P also purchased for resale identical leather goods from wholly owned Puerto Rican subsidiaries. P elected the dollar-value LIFO method of pricing its inventory. One pool was kept for its entire inventory investment. Held, two separate inventory pools were required to be maintained, one for the goods manufactured by petitioner and another for the goods purchased for resale.
Read the full summary
During the years in issue, P was a domestic manufacturer of personal leather goods. P also purchased for resale identical leather goods from wholly owned Puerto Rican subsidiaries. P elected the dollar-value LIFO method of pricing its inventory. One pool was kept for its entire inventory investment. Held, two separate inventory pools were required to be maintained, one for the goods manufactured by petitioner and another for the goods purchased for resale. Sec. 1.472-8(b), Income Tax Regs., applied. In 1975, P began manufacturing leather goods in Puerto Rico. These goods were identical to the…
1Opinion of the Court
Cohen, Judge:
In statutory notices of deficiency dated December 23, 1980, in docket No. 2014-81, and April 2, 1982, in docket No. 8056-82, respondent determined deficiencies in petitioner’s Federal income taxes as follows:
Docket No. TYE Dec. 31— Deficiency
2014-81. 1972 $46,678.05
1974 227,555.41
1975 96,539.30
8056-82. 1977 37,924.00
1978 38,366.00
By agreement of the parties and by order of the Court, these cases were consolidated for purposes of trial, briefing, and opinion. After concessions, the issues for determination are: (1) Whether petitioner, a manufacturer of leather products who used…
2Cases cited14 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Coors v. CommissionerUnited States Tax Court · 1973
9 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Hamilton Industries, Inc. v. CommissionerUnited States Tax Court · 1991
- UFE, Inc. v. CommissionerUnited States Tax Court · 1989
- Consolidated Mfg. v. CommissionerUnited States Tax Court · 1998
- Kohler Co. v. United StatesUnited States Court of Federal Claims · 1995
- Mountain State Ford Truck Sales, Inc. v. CommissionerUnited States Tax Court · 1999
8 more not listed; retrieve them via the Exa API.