Wallingford v. Commissioner
United States Board of Tax Appeals
Petitioners formed a partnership in 1920 and took over cattle at their cost to a predecessor partnership. Held, the petitioners may reflect in their 1920 returns the decrease in the value of the cattle which occurred subsequent to their acquisition in 1920.
1Opinion of the Court
OPINION.
Arundell:
The petitioners claim the right to deduct from their gross income for 1920 the shrinkage in value of cattle in that year. They seek to take this deduction by subtracting the closing inventory *636from the opening inventory for the year. The Commissioner contends that, under section 208 of the Revenue Act of 1918, they are not entitled to compute income on an inventory basis, inasmuch as the inventory basis was not used in prior years.
The purchase by Elmer R. Wallingford of a half interest in the cattle in 1920 effected, at the time of the purchase, a dissolution of the…
2Cited by2 opinions
- Moody-Warren Commercial Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Wallingford v. CommissionerUnited States Board of Tax Appeals · 1926