Legal Opinion

Crown Mfg. Co. v. Commissioner

United States Board of Tax Appeals

Decided May 21, 1928No. Docket No. 9450PublishedCited by 4 opinions

1. Petitioner's inventory was originally priced by one who was familiar with the cotton which he was pricing, and who was in a position to compare the respective values of similar cotton offered by different brokers under different trade names.

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1. Petitioner's inventory was originally priced by one who was familiar with the cotton which he was pricing, and who was in a position to compare the respective values of similar cotton offered by different brokers under different trade names. Held, that the inventory as originally taken was more nearly correct than any which could now be arrived at on the basis of the opinion testimony and should not be disturbed. 2. The machinery in petitioner's mill was operated in excess of the normal daytime operation during the years in question. Held, that 7 per cent is a fair allowance for…

1Opinion of the Court

*42OPINION.

Phillips :

The first question presented to us for determination is the value of the raw materials inventory of the petitioner on December 31, 1920. Petitioner’s inventory was made up of both domestic and foreign cottons and domestic and foreign waste. The cotton is identified by symbols or marks indicating the type and grade of cotton. This inventory was prepared under the supervision of the general manager of the petitioner who purchased practically all of its cotton and who, therefore, knew the qualities of the cotton indicated by each mark. This inventory was also priced by him and…

2Cited by4 opinions

  1. Bibb Mfg. Co. v. RoseCourt of Appeals for the Fifth Circuit · 1936
  2. S. Weisbart & Co. v. CommissionerUnited States Tax Court · 1964
  3. Crown Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  4. Space Controls, Inc. v. CommissionerUnited States Tax Court · 1962

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