Andrew Little, Jr., and Myrn Little v. Commissioner of Internal Revenue

MERRILL, Circuit Judge.

This petition for review of a tax court decision presents a problem of concern to the livestock industry: the proper income tax treatment of the proceeds of sale of breeding stock raised by the taxpayers where the taxpayers are on the accrual system of accounting and following the “unit-livestock-price method” of livestock inventory valuation.

Taxpayers contend that they are entitled to change their breeding herd from an accrual to a cost system of accounting, which would place taxpayers in a more favorable position in reporting the proceeds of sale of breeding animals.…