Brush Wellman, Inc. v. Commissioner
United States Tax Court
Held: Petitioner's practical capacity determinations, which reflected productive capability instead of reflecting average actual production or anticipated sales, satisfy the requirements of the practical capacity regulation, sec. 1.471-11(d)(4), Income Tax Regs.
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Held: Petitioner's practical capacity determinations, which reflected productive capability instead of reflecting average actual production or anticipated sales, satisfy the requirements of the practical capacity regulation, sec. 1.471-11(d)(4), Income Tax Regs. Accordingly, petitioner is entitled under the regulation to deduct the part of fixed indirect production costs which is associated with idle capacity in the year of production rather than waiting to deduct it in the year in which the produced goods are sold.
1Opinion of the Court
Brush Wellman, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Brush Wellman, Inc. v. Commissioner
Docket No. 12978-78
United States Tax Court
79 T.C. 160; 1982 U.S. Tax Ct. LEXIS 59; 79 T.C. No. 11;
July 28, 1982, Filed
Decision will be entered under Rule 155.
Held: Petitioner's practical capacity determinations, which reflected productive capability instead of reflecting average actual production or anticipated sales, satisfy the requirements of the practical capacity regulation, sec. 1.471-11(d)(4), Income Tax Regs. Accordingly, petitioner is entitled under the regulation to…
2Cases cited7 opinions
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Morrissey v. CommissionerSupreme Court of the United States · 1935
- Larson v. CommissionerUnited States Tax Court · 1976
- Maple Leaf Farms, Inc. v. CommissionerUnited States Tax Court · 1975
- Bangor Punta Operations, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1972
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