Goodenow v. Commissioner
United States Tax Court
Respondent determined that petitioner, a farmer, reporting on the accrual basis, overstated his opening inventory for 1947 in computing his gross farm profits.
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Respondent determined that petitioner, a farmer, reporting on the accrual basis, overstated his opening inventory for 1947 in computing his gross farm profits. The notice of deficiency was sent more than 3 years but less than 5 years from the date petitioner filed his final income tax return for 1947. Held, respondent's determination is correct and section 275 (c) of the 1939 Code is applicable since an overstatement of an item of cost in the computation of gross income is an omission from gross income of an amount properly includible, within the meaning of that section. Held, further, gross…
1Opinion of the Court
OPINION.
Rice, Judge:
This proceeding involves a deficiency in income tax in the amount of $625.50 for the year 1947 determined by the respondent under the provisions of the Internal Revenue Code of 1939. The deficiency notice, which is the basis of this proceeding, was mailed to petitioner more than 3 but less than 5 years after his 1947 income tax return was filed.
The issues to be decided are: (1) Whether the respondent erred in allowing the cost of certain livestock sold during the year to be deducted only once by petitioner in computing his income, rather than twice; and (2) if not, whether…
2Cases cited4 opinions
- Uptegrove Lumber Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
- American Found. Co. v. CommissionerUnited States Tax Court · 1943
- American Liberty Oil Co. v. CommissionerUnited States Tax Court · 1942
- Estate of Gibbs v. CommissionerUnited States Tax Court · 1954
3Cited by16 opinions
- Lawrence v. CommissionerUnited States Tax Court · 1957
- Colony, Inc. v. CommissionerUnited States Tax Court · 1956
- Romine v. Comm'rUnited States Tax Court · 1956
- John E. Goodenow v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1956
- North American Life & Casualty Co. v. CommissionerUnited States Tax Court · 1974
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