Legal Opinion

Auburn Packing Co. v. Commissioner

United States Tax Court

Decided August 27, 1973No. Docket No. 7347-70PublishedCited by 38 opinions

Held, in these circumstances, respondent cannot require the petitioner, a livestock raiser, who has consistently used the unit-livestock-price method of inventory valuation, to change from that method to the lower of cost or market method.

1Opinion of the Court

Dawson, Judge:

Respondent determined a deficiency in petitioner’s Federal income tax in the amount of $210,272 for the taxable year ended June 30,1967.

The principal issue presented for decision is whether, under sections 446(b) and 471, I. R. C. 1954,1 the respondent can require petitioner to change from the unit-livestock-price method of inventory valuation to the lower of cost or market method, on the ground that the unit-livestock-price method does not clearly reflect petitioner’s income. If the respondent prevails on this point then two additional issues arise. They are: (1) Whether, by…

2Cases cited11 opinions

  1. Brown v. HelveringSupreme Court of the United States · 1934
  2. United States v. CattoSupreme Court of the United States · 1966
  3. Ft. Howard Paper Co. v. CommissionerUnited States Tax Court · 1967
  4. Photo-Sonics, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1966
  5. Wilkinson-Beane, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1970

6 more not listed; retrieve them via the Exa API.

3Cited by38 opinions

  1. Madison Gas & Electric Co. v. CommissionerUnited States Tax Court · 1979
  2. Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
  3. Prabel v. CommissionerUnited States Tax Court · 1988
  4. Van Raden v. CommissionerUnited States Tax Court · 1979
  5. Peninsula Steel Products & Equipment Co. v. CommissionerUnited States Tax Court · 1982

33 more not listed; retrieve them via the Exa API.

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