Singer Sewing Machine Co. v. Commissioner
United States Tax Court
1. Inventories -- Opening After Discontinuance of Consolidated Returns. -- A proper downward adjustment of the opening inventory on the first separate return after a period for which consolidated returns were filed, under the circumstances of this case, is the equivalent of the amount of intercompany profit represented in that inventory which has escaped tax up to the date of the opening inventory in question. 2. Deductions -- Ordinary and Necessary Expenses -- Donations by…
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1. Inventories -- Opening After Discontinuance of Consolidated Returns. -- A proper downward adjustment of the opening inventory on the first separate return after a period for which consolidated returns were filed, under the circumstances of this case, is the equivalent of the amount of intercompany profit represented in that inventory which has escaped tax up to the date of the opening inventory in question. 2. Deductions -- Ordinary and Necessary Expenses -- Donations by a Corporation. -- Donations by a corporation to local charities, held to have been ordinary and necessary expenses.
1Opinion of the Court
OPINION.
MuRdock, Judge:
The petitioner, with its parent and other affiliates, had been filing consolidated returns for many years. The law was changed in 1934 and those companies no longer had the privilege of joining in a consolidated return. The petitioner has changed over to a separate return for 1934 and the question is, What is a proper amount for its opening inventory for that year ? Save for some special problem inherent in the process of changing over, the petitioner would concededly be entitled to use cost to it or market value, whichever is lower.
The Commissioner contends that the…
2Cited by14 opinions
- Trinco Industries, Inc. v. CommissionerUnited States Tax Court · 1954
- Wm. T. Stover Co. v. CommissionerUnited States Tax Court · 1956
- John Wanamaker Philadelphia, Inc. v. The United States. John Wanamaker Philadelphia, Inc. (Successor by Merger to John Wanamaker New York, Inc.) v. The United StatesUnited States Court of Claims · 1966
- John Wanamaker Philadlephia, Inc. v. United StatesUnited States Court of Claims · 1966
- Olivier Company v. PattersonDistrict Court, N.D. Alabama · 1957
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