St. James Sugar Cooperative, Inc., Cross v. United States of America, Cross

AINSWORTH, Circuit Judge:

This is an appeal by the United States (Internal Revenue Service) from a judgment of the district court entered in .favor of taxpayer, St. James Sugar Cooperative, Inc., for a refund of $1,818,612.55 in income taxes for St. James’ fiscal year ending March 31, 1975. The court concluded that under the facts of this case and the provisions of 26 U.S.C. § 471, market not to exceed net realizable value is a permissible and accurate method of valuing ending inventory for an agricultural cooperative. Thus, the Government’s conclusion to the contrary which formed the basis of…