Hamilton Industries, Inc. v. Commissioner
United States Tax Court
P purchased the assets of M and T in separate transactions, assigning a portion of the purchase price to inventory acquired from M and T. The value assigned to the purchased inventory was less than the value assigned to it by the targets under the first-in, first-out (FIFO) convention. Such assigned value was used as the base year cost for P's inventory under P's dollar value last-in, first-out (LIFO) method of inventory accounting.
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P purchased the assets of M and T in separate transactions, assigning a portion of the purchase price to inventory acquired from M and T. The value assigned to the purchased inventory was less than the value assigned to it by the targets under the first-in, first-out (FIFO) convention. Such assigned value was used as the base year cost for P's inventory under P's dollar value last-in, first-out (LIFO) method of inventory accounting. Held, R's determination that inventory purchased in the acquisitions of M and T should be separated from raw materials purchased or goods produced subsequent to…
1Opinion of the Court
WELLS, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income tax:
TYE June 30 1977
1980 ....
1981
1982
1983
1984
Deficiency
$31,210
755,228
1,952,926
1,464,788
197,751
129,846
After concessions, the issues remaining for decision are: (1) Whether respondent’s determination that inventory acquired as part of petitioner’s purchases of other businesses should be treated as pools or items separate from raw materials purchased or inventory manufactured subsequent to such acquisitions constituted a change in petitioner’s method of accounting for inventories; (2) whether respondent…
2Cases cited61 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- Schulde v. CommissionerSupreme Court of the United States · 1963
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- Pacific Enters. & Subsidiaries v. CommissionerUnited States Tax Court · 1993
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