Thor Power Tool Co. v. Commissioner
United States Tax Court
Where the petitioner valued its inventory at the lower of cost or market, the Commissioner did not abuse the discretion vested in him under sec. 471, I.R.C. 1954, by reducing the petitioner's cost of goods sold and restoring to income the amount by which the petitioner reduced the value of its 1964 closing inventory to reflect the current net realizable value rather than current replacement cost of units of inventory determined to be excess under procedures in accordance…
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Where the petitioner valued its inventory at the lower of cost or market, the Commissioner did not abuse the discretion vested in him under sec. 471, I.R.C. 1954, by reducing the petitioner's cost of goods sold and restoring to income the amount by which the petitioner reduced the value of its 1964 closing inventory to reflect the current net realizable value rather than current replacement cost of units of inventory determined to be excess under procedures in accordance with generally accepted accounting principles. In computing petitioner's cost of goods sold for the taxable year 1964, the…
1Opinion of the Court
Goffe, Judge:
The Commissioner determined deficiencies in petitioner’s Federal income tax as follows:
Taxable
year Deficiency
1963 _ $545,997.64
1965 _ 59,701.35
The deficiency for the taxable year 1963 results primarily from a disallowance in full of a net operating loss deduction carried back from the taxable year 1964. Adjustments to the taxable year 1964 are, therefore, involved herein. Certain adjustments in the statutory notice of deficiency have been resolved by the parties leaving the following issues for decision:(1) Where the petitioner valued its inventory at the lower of cost or market,…
2Cases cited28 opinions
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Burnet v. LoganSupreme Court of the United States · 1931
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- Lucas v. Kansas City Structural Steel Co.Supreme Court of the United States · 1930
23 more not listed; retrieve them via the Exa API.
3Cited by39 opinions
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Madison Gas & Electric Co. v. CommissionerUnited States Tax Court · 1979
- Brountas v. CommissionerUnited States Tax Court · 1979
- Paccar, Inc. And Subsidiaries v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
- Hamilton Industries, Inc. v. CommissionerUnited States Tax Court · 1991
34 more not listed; retrieve them via the Exa API.