Legal Opinion

Hamilton Industries, Inc. v. Commissioner

United States Tax Court

Decided July 30, 1991No. Docket No. 24006-88PublishedCited by 38 opinions

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.

Read the full summary

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

  1. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  2. Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
  3. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
  4. American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
  5. Schulde v. CommissionerSupreme Court of the United States · 1963

56 more not listed; retrieve them via the Exa API.

3Cited by38 opinions

  1. Ansley-Sheppard-Burgess Co. v. CommissionerUnited States Tax Court · 1995
  2. Bank One Corp. v. Comm'rUnited States Tax Court · 2003
  3. Ford Motor Co. v. CommissionerUnited States Tax Court · 1994
  4. Ford Motor Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1996
  5. Pacific Enters. & Subsidiaries v. CommissionerUnited States Tax Court · 1993

33 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API