Legal Opinion

Sierracin Corp. v. Commissioner

United States Tax Court

Decided March 9, 1988No. Docket No. 28569-83Published

Petitioner used the completed-contract method to account for income from several of its manufacturing divisions. Held: (1) Items produced by two of petitioner's divisions were "unique items" within the meaning of sec. 1.451-3(b)(1)(ii), Income Tax Regs., and petitioner's use of the completed-contract method to account for income from these two divisions consequently was proper; and (2) contracts entered into by those two divisions need not be severed by delivery because each…

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Petitioner used the completed-contract method to account for income from several of its manufacturing divisions. Held: (1) Items produced by two of petitioner's divisions were "unique items" within the meaning of sec. 1.451-3(b)(1)(ii), Income Tax Regs., and petitioner's use of the completed-contract method to account for income from these two divisions consequently was proper; and (2) contracts entered into by those two divisions need not be severed by delivery because each delivery was not independently priced. Held, further, respondent's determinations as to petitioner's other divisions…

1Opinion of the Court

Sierracin Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent

Sierracin Corp. v. Commissioner

Docket No. 28569-83

United States Tax Court

90 T.C. 341; 1988 U.S. Tax Ct. LEXIS 27; 90 T.C. No. 27;

March 9, 1988; As amended March 9, 1988 March 9, 1988, Filed

Decision will be entered under Rule 155.

Petitioner used the completed-contract method to account for income from several of its manufacturing divisions. Held: (1) Items produced by two of petitioner's divisions were "unique items" within the meaning of sec. 1.451-3(b)(1)(ii), Income Tax Regs., and petitioner's use of the…

2Cases cited12 opinions

  1. Lucas v. American Code Co.Supreme Court of the United States · 1930
  2. Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
  3. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
  4. Peninsula Steel Products & Equipment Co. v. CommissionerUnited States Tax Court · 1982
  5. Reco Industries, Inc. v. CommissionerUnited States Tax Court · 1984

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