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
HAMILTON INDUSTRIES, INC., SUCCESSOR OF MAYLINE COMPANY, INC. AND SUBSIDIARY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hamilton Industries, Inc. v. Commissioner
Docket No. 24006-88
United States Tax Court
97 T.C. 120; 1991 U.S. Tax Ct. LEXIS 64; 97 T.C. No. 9;
July 30, 1991, Filed
Decision will be entered under Rule 155.
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,…
2Cases cited62 opinions
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- 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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