Legal Opinion

Fruehauf Trailer Co. v. Commissioner

United States Tax Court

Decided April 13, 1964No. Docket Nos. 88221, 89949PublishedCited by 63 opinions

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

  1. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  2. Dobson v. CommissionerSupreme Court of the United States · 1944
  3. Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
  4. United States v. LudeySupreme Court of the United States · 1927
  5. United States v. LewisSupreme Court of the United States · 1951

29 more not listed; retrieve them via the Exa API.

3Cited by63 opinions

  1. Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
  2. Sandor v. CommissionerUnited States Tax Court · 1974
  3. Coors v. CommissionerUnited States Tax Court · 1973
  4. Wayne Bolt & Nut Co. v. CommissionerUnited States Tax Court · 1989
  5. Photo-Sonics, Inc. v. CommissionerUnited States Tax Court · 1964

58 more not listed; retrieve them via the Exa API.

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