Peninsula Steel Products & Equipment Co. v. Commissioner
United States Tax Court
Petitioner manufactures pollution control equipment under short-term and long-term purchase orders or contracts. Petitioner maintains raw materials and work-in-process inventory accounts. During the manufacturing process, costs of raw materials, labor, and overhead are accumulated in work-in-process inventory accounts.
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Petitioner manufactures pollution control equipment under short-term and long-term purchase orders or contracts. Petitioner maintains raw materials and work-in-process inventory accounts. During the manufacturing process, costs of raw materials, labor, and overhead are accumulated in work-in-process inventory accounts. When performance is completed under a purchase order or contract, income is recognized and the associated costs are relieved from inventory and charged to cost of goods sold. A significant portion of the work performed by petitioner during the years in issue related to…
1Opinion of the Court
Chabot, Judge:
Respondent determined deficiencies in Federal corporation income taxes against petitioner (see note 4 infra) as follows:
TYE June 30— Deficiency
1974.$189,267
1975. 432,421
After concessions1 by the parties, the issues for decision are:(1) Whether petitioner reported income from long-term contracts using the completed contract method of accounting or the accrual shipment method;(2) Whether respondent may change petitioner’s method of accounting for long-term contracts, which accumulates manufacturing costs in inventory accounts; and(3) Whether respondent may change petitioner’s…
2Cases cited55 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Commissioner v. HansenSupreme Court of the United States · 1959
- Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Madison Gas and Electric Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1980
50 more not listed; retrieve them via the Exa API.
3Cited by63 opinions
- Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
- Prabel v. CommissionerUnited States Tax Court · 1988
- Ansley-Sheppard-Burgess Co. v. CommissionerUnited States Tax Court · 1995
- Hamilton Industries, Inc. v. CommissionerUnited States Tax Court · 1991
- Reco Industries, Inc. v. CommissionerUnited States Tax Court · 1984
58 more not listed; retrieve them via the Exa API.