Fruehauf Trailer Co. v. Commissioner
United States Tax Court
Petitioner was incorporated in 1918. It manufactured and sold commercial truck trailers. It kept its books and filed its returns on a calendar year accrual basis. About 1926 petitioner began to acquire used trailers as trade-ins or by repossession. Although petitioner inventoried its manufactured trailers at the lower of cost or market, it began inventorying its used trailers at $ 1 per unit.
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Petitioner was incorporated in 1918. It manufactured and sold commercial truck trailers. It kept its books and filed its returns on a calendar year accrual basis. About 1926 petitioner began to acquire used trailers as trade-ins or by repossession. Although petitioner inventoried its manufactured trailers at the lower of cost or market, it began inventorying its used trailers at $ 1 per unit. This practice was not disturbed by respondent for the years prior to 1942. While auditing the years 1942 through 1945, a revenue agent in 1948 proposed to change the closing inventory for 1945 to the…
1Opinion of the Court
Akundell, Judge:
In these consolidated proceedings respondent, in docket No. 88221, determined deficiencies in income tax for the calendar years 1954 and 1955 of $2,955,903.12 and $3,717,622.52, respectively, and, in docket No. 89949, a deficiency in income tax for the calendar year 1956 of $3,296,142.33.
In an amended petition filed in docket No. 88221, “Petitioner also contends that its income taxes for 1955 are overpaid by the amount of $5,632,533.86.”
In its petition and amended petition filed in docket No. 89949, “Petitioner also contends that its income taxes for 1956 are overpaid by the…
2Cases cited34 opinions
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- United States v. LewisSupreme Court of the United States · 1951
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