Legal Opinion

Moody-Warren Commercial Co. v. Commissioner

United States Board of Tax Appeals

Decided January 23, 1934No. Docket No. 62495PublishedCited by 1 opinion

Petitioner undertook to inventory feeder lambs on hand at the end of the taxable year on the so-called "farm-price method" and deduct from the gross income the difference between the cost of lambs and the estimated farm-price thereof. Held, that the inventory method used did not truly reflect income for the year in question and that petitioner, even if entitled to use the farm-price method, failed to comply with the plain requirements of article 106(2)(b) of Regulations 74.

1Opinion of the Court

*889OPINION.

Lansdon:

The petitioner claims that its income in the taxable year should be reduced by an amount which it alleges represents a Joss sustained in its sheep-feeding operations. The loss claimed is the difference between the cost of feeder lambs purchased some months prior to December 31, 1929, plus feeding costs, and the alleged farm-price value of such lambs at that date. In support of its contention it relies on article 106 (2) (b) of Regulations 14 which, so far as material here, is as follows:

Because of the difficulty of ascertaining actual cost of live stock and other farm…

2Cases cited2 opinions

  1. Twin Ports Bridge Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  2. Wallingford v. CommissionerUnited States Board of Tax Appeals · 1926

3Cited by1 opinion

  1. Moody-Warren Commercial Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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