Legal Opinion

Guardian Indus. Corp. v. Commissioner

United States Tax Court

Decided September 11, 1991No. Docket No. 27308-87Published

Ps engaged in the photo-finishing business. Both the photographic film Ps received from their customers for developing and the paper purchased by Ps for use in making prints contain silver halide compounds, which are removed during the developing process. Ps extracted silver-bearing waste materials from the chemical solutions used in photo-finishing and sold them in the ordinary course of their photo-finishing business.

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Ps engaged in the photo-finishing business. Both the photographic film Ps received from their customers for developing and the paper purchased by Ps for use in making prints contain silver halide compounds, which are removed during the developing process. Ps extracted silver-bearing waste materials from the chemical solutions used in photo-finishing and sold them in the ordinary course of their photo-finishing business. The sales were frequent and generated substantial income. Ps originally reported the sales proceeds as ordinary income on their tax returns, but subsequently amended such…

1Opinion of the Court

GUARDIAN INDUSTRIES CORP. AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Guardian Indus. Corp. v. Commissioner

Docket No. 27308-87

United States Tax Court

97 T.C. 308; 1991 U.S. Tax Ct. LEXIS 80; 97 T.C. No. 21;

September 11, 1991, Filed

Decision will be entered under Rule 155.

Ps engaged in the photo-finishing business. Both the photographic film Ps received from their customers for developing and the paper purchased by Ps for use in making prints contain silver halide compounds, which are removed during the developing process. Ps extracted silver-bearing waste…

2Cases cited71 opinions

  1. Malat v. RiddellSupreme Court of the United States · 1966
  2. Woodward v. CommissionerSupreme Court of the United States · 1970
  3. Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
  4. Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
  5. Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980

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