Hamill v. Commissioner
United States Board of Tax Appeals
A partnership engaged in handling commercial paper and securities in various ways, including the purchase of a relatively small amount of securities for resale, held, upon the evidence, not entitled to the use of an inventory as to such small part of its business.
1Opinion of the Court
*957OPINION.
SteRnhagen :
Since each of these proceedings is derivative from the determination of the partnership income, the partnership will be treated as if it were the single party in interest. On the part*958nership return for 1930 (not in evidence), it deducted $121,415 as an inventory loss, and this item the respondent disallowed with a somewhat ambiguous statement. At the beginning of the trial the petitioners conceded that the deduction was in any event too large because the partnership had in its computation omitted to apply the first-in first-out rule to securities which had been sold during…
2Cases cited11 opinions
- Lucas v. Kansas City Structural Steel Co.Supreme Court of the United States · 1930
- Blair v. Oesterlein MacHine Co.Supreme Court of the United States · 1927
- Thomas Shoe Co. v. CommissionerUnited States Board of Tax Appeals · 1924
- Atlantic Coast Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Adirondack Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1931
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3Cited by3 opinions
- Hamill v. CommissionerUnited States Board of Tax Appeals · 1934
- Securities-Allied Corp. v. CommissionerUnited States Board of Tax Appeals · 1937
- The Coca-Cola Company and Subsidiaries v. CommissionerUnited States Tax Court · 2020