Legal Opinion

Thomas Shoe Co. v. Commissioner

United States Board of Tax Appeals

Decided December 2, 1924No. Docket No. 209PublishedCited by 21 opinions

A contribution to a fund raised by business organizations to purchase land upon which a naval ordnance plant is to be erected is not an ordinary and necessary expense in carrying on a wholesale shoe business. Inventories used in computing the cost of goods sold must be computed both at the beginning and end of each year on substantially the same basis. Discounts, held here to be trade discounts, if deducted in one such inventory, must be deducted in both.

1Opinion of the Court

*125OPINION.

James: This appeal arises upon two assignments of error, of which one relates to the year 1917 and the other to all years subsequent thereto. The taxpayer alleges that its contribution of $500, as set forth in the findings of fact, was an ordinary and necessary expense for the year 1917. It alleges that the adjustments of inventory made by the agent and confirmed by the Commissioner are arbitrary and distort its income for the taxable year 1918, by changing in that year the substantial basis upon which its inventory had been theretofore and was then and thereafter taken.

We are of the…

2Cases cited1 opinion

  1. Baldwin Locomotive Works v. McCoachDistrict Court, E.D. Pennsylvania · 1914

3Cited by21 opinions

  1. Fruehauf Trailer Co. v. CommissionerUnited States Tax Court · 1964
  2. Adam, Meldrum & Anderson Co. v. CommissionerUnited States Board of Tax Appeals · 1933
  3. Evening Star Newspaper Co. v. CommissionerUnited States Board of Tax Appeals · 1933
  4. Hamill v. CommissionerUnited States Board of Tax Appeals · 1934
  5. E. J. Scheer, Inc. v. CommissionerUnited States Tax Court · 1949

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