Kohler Co. v. United States

OPINION

HODGES, Judge.

This case raises two issues involving Koh-ler Co., a Wisconsin corporation, that otherwise are unrelated: (1) Was Kohler’s foreign subsidiary required to incorporate in Canada so that it could be included in Kohler’s consolidated return pursuant to United States tax laws and regulations; and (2) Was the taxpayer’s income clearly reflected using the Last In, First Out (LIFO) method of accounting when it treated goods purchased at a substantial discount the same as goods later manufactured. The answer in both instances is No.

I

OVERVIEW

A CANADIAN SUBSIDIARY

IRS permits an…