Fischer Industries, Inc. v. Commissioner
United States Tax Court
Prior to 1975, Mayfran, a member of P's consolidated group, calculated the value of its closing inventory under the first-in, first-out (FIFO) method of inventory accounting. For its taxable year 1975 and each subsequent taxable year, Mayfran correctly calculated the value of its closing inventory under the last-in, first-out (LIFO) method.
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Prior to 1975, Mayfran, a member of P's consolidated group, calculated the value of its closing inventory under the first-in, first-out (FIFO) method of inventory accounting. For its taxable year 1975 and each subsequent taxable year, Mayfran correctly calculated the value of its closing inventory under the last-in, first-out (LIFO) method. P failed to file a Form 970, Application to Use LIFO Inventory Method, or the information requested by Form 970, on or with its original, consolidated Federal income tax return for the taxable year 1975. The information requested by Form 970 was, however,…
1Opinion of the Court
WILLIAMS, Judge:
The Commissioner determined deficiencies in petitioners’ Federal income tax for each of the taxable years 1975 through 1978 and for 1980 and additions to tax for fraud pursuant to section 6653(b)1 in the following amounts:
TYE Apr. 30-Deficiency Sec. 6653(b) additions to tax1
1975 $349,436 $174,718
1976 174,699 87,335
1977 246.311 123,156
1978 22,698 (not applicable)
19802 177.311 (not applicable)
1 Respondent, by amendment to answer, proposed increases in the additions to tax pursuant to sec. 6653(b); the proposed revised additions are as follows: for the taxable year 1975 —…
2Cases cited18 opinions
- Knight-Ridder Newspapers, Inc. v. United StatesCourt of Appeals for the Eleventh Circuit · 1984
- Reaver v. CommissionerUnited States Tax Court · 1964
- Alexander v. Cosden Pipe Line Co.Supreme Court of the United States · 1934
- Dougherty v. CommissionerUnited States Tax Court · 1973
- Columbia Iron & Metal Co. v. CommissionerUnited States Tax Court · 1973
13 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Samueli v. Comm'rUnited States Tax Court · 2009
- Fischer Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1988
- Bedrosian v. Comm'rUnited States Tax Court · 2014
- Thurman v. CommissionerUnited States Tax Court · 1998
- John Bedrosian v. CirCourt of Appeals for the Ninth Circuit · 2019
10 more not listed; retrieve them via the Exa API.