J. W. & A. P. Howard Co. v. Commissioner
United States Board of Tax Appeals
Petitioner priced the inventories in its return for the fiscal year ended March 31, 1920, on the basis of cost, such return having been filed prior to the issuance of Treasury Decision 3108, which gave taxpayers the authority to price their inventories on the basis of cost or market, whichever was lower, regardless of their past practice.
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Petitioner priced the inventories in its return for the fiscal year ended March 31, 1920, on the basis of cost, such return having been filed prior to the issuance of Treasury Decision 3108, which gave taxpayers the authority to price their inventories on the basis of cost or market, whichever was lower, regardless of their past practice. In the return filed for the fiscal year ended March 31, 1921, petitioner priced its closing inventory on the basis of cost or market, whichever was lower. In November, 1921, petitioner submitted revised inventories for the fiscal year ended March 31, 1920,…
1Opinion of the Court
*1098 OPINION.
Love :
Prior to the fiscal year ended March 31, 1921, the petitioner priced its inventories on the basis of “cost,” but when it filed its return on July 15, 1921, for the fiscal year ended March 31, 1921, it priced its closing inventory for such year on the basis of “cost or market, whichever was lower,” using a cost basis at the beginning of such year, and the result shown for the year being a substantial loss. What loss would have been shown (though apparently there would have been a loss) had the opening and closing inventories been on the same basis (that is, cost or cost or…
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