El Dorado Oil Works v. Commissioner
United States Board of Tax Appeals
Petitioner, engaged in the manufacture of coconut oil in San Francisco, purchased copra in the Philippines through its agents there, who were authorized to buy at a certain price and to whom funds were forwarded sufficient to cover the price authorized.
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Petitioner, engaged in the manufacture of coconut oil in San Francisco, purchased copra in the Philippines through its agents there, who were authorized to buy at a certain price and to whom funds were forwarded sufficient to cover the price authorized. In the years 1932 to 1935 copra was purchased at prices under those authorized and the excess of the funds advanced to petitioner's agents over the prices actually paid was retained by the agents and was carried on petitioner's books as "Manila Reserve", from which, in 1936, certain sums were transferred to petitioner's surplus. In 1937 the…
1Opinion of the Court
*996OPINION.
Kern :
Petitioner, with its main office at San Francisco, had a purchasing department at Manila through which it bought copra. The Manila agents bought from many small traders in the South Seas, but in later years mainly from those in the Philippine Islands, and at varying prices. The petitioner would name a certain price and send the Manila agency cash advances sufficient to meet purchases made at this price. The agent would buy at a price around that *997named, sometimes above but more often below. The named price, in short, was only a norm, and the petitioner’s advances did not…
2Cited by10 opinions
- Ross Glove Co. v. CommissionerUnited States Tax Court · 1973
- Gaylord v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1946
- Policy Holders Agency, Inc. v. CommissionerUnited States Tax Court · 1963
- Sebring v. CommissionerUnited States Tax Court · 1989
- El Dorado Oil Works v. CommissionerUnited States Board of Tax Appeals · 1942
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