Willamette Industries, Inc. v. Commissioner of Internal Revenue

The Commissioner determined deficiencies in income taxes for Willamette Industries, Inc. (“Willamette”) for the years 1978-1983. Willamette challenges the tax court’s rulings on two separate issues in connection with these deficiencies: (1) whether, for purposes of 26 U.S.C. § 631(a) 1 , the fair market value of timber logged by Willamette and its subsidiaries on United States Forest Service lands includes the price of building the logging roads required by the Forest Service as part of its contract; and (2) whether Willamette properly deducted $20 million pursuant to 26 U.S.C. § 461(f) on…