Legal Opinion

Estate of Cohn v. Commissioner

United States Tax Court

Decided March 25, 1974No. Docket No. 2299-71PublishedCited by 3 opinions

Petitioner, Albert Cohn, for many years prior to his demise, and specifically from Jan. 1, 1964, until his death on July 18, 1968, owned and operated National Rubber Footwear Co., as a sole proprietorship. National was a wholesaler of tennis shoes and rubber boots of a "seconds" quality. Prior to his death, petitioner priced the inventories himself; and none of his employees ever saw his computations or the resulting profit-and-loss statements or the balance sheets.

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Petitioner, Albert Cohn, for many years prior to his demise, and specifically from Jan. 1, 1964, until his death on July 18, 1968, owned and operated National Rubber Footwear Co., as a sole proprietorship. National was a wholesaler of tennis shoes and rubber boots of a "seconds" quality. Prior to his death, petitioner priced the inventories himself; and none of his employees ever saw his computations or the resulting profit-and-loss statements or the balance sheets. In preparing National's periodic financial statements, his accountant relied upon petitioner's inventory computations. After…

1Opinion of the Court

Withex, Judge:

Respondent determined deficiencies in Federal income taxes against the petitioners for the taxable years 1966 and 1968, as follows:

7 ear Deficiency

1966 _$78, 478.08

1968 _ 199,441. 35

The sole issue presented for our consideration is whether the petitioners are entitled to change inventories which were previously reported by National Rubber Footwear Co., a sole proprietorship, during the years 1964 through 1968, inclusive, or whether they are required to report National’s beginning 1968 inventory in the same amount as National’s originally reported ending 1967 inventory in order…

2Cases cited8 opinions

  1. Steel or Bronze Piston Ring Corp. v. CommissionerUnited States Tax Court · 1949
  2. American Pitch Pine Export Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
  3. John Wanamaker v. CommissionerCourt of Appeals for the Third Circuit · 1932
  4. John Wanamaker Philadelphia v. CommissionerUnited States Board of Tax Appeals · 1931
  5. O. A. Steiner Tire Co. v. CommissionerUnited States Board of Tax Appeals · 1928

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

3Cited by3 opinions

  1. De Fusco v. CommissionerUnited States Tax Court · 1979
  2. Estate of Cohn v. CommissionerUnited States Tax Court · 1974
  3. Green v. CommissionerUnited States Tax Court · 1974

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