Wayne Bolt & Nut Co. v. Commissioner
United States Tax Court
P was engaged in the business of selling metal fasteners. Prior to fiscal year 1982, P determined opening and ending inventory using a perpetual book inventory record keeping system. P verified book inventory by taking a partial physical inventory. For fiscal year 1982, P determined both opening and ending inventory on the basis of a complete physical inventory that was completed several months after the close of the fiscal year.
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P was engaged in the business of selling metal fasteners. Prior to fiscal year 1982, P determined opening and ending inventory using a perpetual book inventory record keeping system. P verified book inventory by taking a partial physical inventory. For fiscal year 1982, P determined both opening and ending inventory on the basis of a complete physical inventory that was completed several months after the close of the fiscal year. This physical inventory, after adjustments, indicated that opening inventory for fiscal year 1982 was ten times greater than ending inventory reflected in the books…
1Opinion of the Court
RUWE, Judge:
Respondent determined a deficiency of $1,091,362 in petitioner’s Federal income tax for the taxable year ended February 28, 1982. The issues for decision are whether petitioner correctly valued its opening inventory and, if so, whether petitioner changed its method of accounting so as to require adjustments pursuant to section 481.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts and attached exhibits are incorporated herein by this reference.
Petitioner, a Michigan corporation, is engaged in the business of selling metal fasteners.…
2Cases cited17 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Achiro v. CommissionerUnited States Tax Court · 1981
- Knight-Ridder Newspapers, Inc. v. United StatesCourt of Appeals for the Eleventh Circuit · 1984
- McSpadden v. CommissionerUnited States Tax Court · 1968
- Graff Chevrolet Company v. Ellis Campbell, Jr., District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1965
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