Legal Opinion

Amity Leather Products Co. v. Commissioner

United States Tax Court

Decided May 17, 1984No. Docket Nos. 2014-81, 8056-82Published

During the years in issue, P was a domestic manufacturer of personal leather goods. P also purchased for resale identical leather goods from wholly owned Puerto Rican subsidiaries. P elected the dollar-value LIFO method of pricing its inventory. One pool was kept for its entire inventory investment. Held, two separate inventory pools were required to be maintained, one for the goods manufactured by petitioner and another for the goods purchased for resale.

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During the years in issue, P was a domestic manufacturer of personal leather goods. P also purchased for resale identical leather goods from wholly owned Puerto Rican subsidiaries. P elected the dollar-value LIFO method of pricing its inventory. One pool was kept for its entire inventory investment. Held, two separate inventory pools were required to be maintained, one for the goods manufactured by petitioner and another for the goods purchased for resale. Sec. 1.472-8(b), Income Tax Regs., applied. In 1975, P began manufacturing leather goods in Puerto Rico. These goods were identical to the…

1Opinion of the Court

Amity Leather Products Co., Petitioner v. Commissioner of Internal Revenue, Respondent

Amity Leather Products Co. v. Commissioner

Docket Nos. 2014-81, 8056-82

United States Tax Court

82 T.C. 726; 1984 U.S. Tax Ct. LEXIS 73; 82 T.C. No. 56;

May 17, 1984, Filed

Decisions will be entered under Rule 155.

During the years in issue, P was a domestic manufacturer of personal leather goods. P also purchased for resale identical leather goods from wholly owned Puerto Rican subsidiaries. P elected the dollar-value LIFO method of pricing its inventory. One pool was kept for its entire inventory investment.…

2Cases cited15 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
  3. Sanford v. CommissionerUnited States Tax Court · 1968
  4. William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
  5. Coors v. CommissionerUnited States Tax Court · 1973

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