Rogers, Brown & Crocker Bros., Inc. v. Commissioner
United States Board of Tax Appeals
1. Petitioner, organized in 1925 and doing a jobbing business in a large group of unrelated commodities, took inventories for 1927, 1928, and 1929 at cost. As to inventory practice in 1925 and 1926 the record is silent. The 1928 return stated that inventories were valued at the lower of cost or market, while the 1929 return stated that inventories were valued at cost.
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1. Petitioner, organized in 1925 and doing a jobbing business in a large group of unrelated commodities, took inventories for 1927, 1928, and 1929 at cost. As to inventory practice in 1925 and 1926 the record is silent. The 1928 return stated that inventories were valued at the lower of cost or market, while the 1929 return stated that inventories were valued at cost. Held, that the statement in the 1928 return, which is contrary to fact, was not the exercise of an election of basis for valuing inventories that is binding as to the taxable year 1929; and that petitioner, having consistently…
1Opinion of the Court
OPINION.
Arundell:
Respondent determined a deficiency of $7,345.21 in petitioner’s 1929 income tax. Petitioner alleges that the determination is erroneous, in that respondent (1) overstated gross profit from trading, and (2) disallowed a deduction of $41,744.63 for salaries incurred within the year.
Petitioner, a Delaware corporation, was organized on June 8, 1925, succeeding to the businesses of two partnerships. At first its principal business was selling pig iron and other metals on a commission basis. In 1929 its commission sales amounted to $3,447,-051.80 and its sales for its own account…
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- Rio Grande Bldg. & Loan Ass'n v. CommissionerUnited States Tax Court · 1961
- Rogers, Brown & Crocker Bros., Inc. v. CommissionerUnited States Board of Tax Appeals · 1935