Garth v. Commissioner
United States Tax Court
Petitioners owned all of the capital stock of Garth's Poultry & Egg Service, Inc., which together with several other entities owned by petitioners comprised an integrated poultry operation for the production and sale of chickens and eggs. The chickens were raised primarily for the production of eggs but they were also sold for meat at the end of their normal egg-laying cycle, which was about 12 months.
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Petitioners owned all of the capital stock of Garth's Poultry & Egg Service, Inc., which together with several other entities owned by petitioners comprised an integrated poultry operation for the production and sale of chickens and eggs. The chickens were raised primarily for the production of eggs but they were also sold for meat at the end of their normal egg-laying cycle, which was about 12 months. Held, Garth's flocks of laying hens were properly includable in inventory. Held, further, Garth's farm-price method of valuing its flocks of hens for inventory purposes, which it had used in…
1Opinion of the Court
DRENNEN, Judge:
Kespondent asserted transferee liability against petitioners as transferees of the assets of Garth’s Poultry & Egg Service, Inc. (hereinafter referred to as Garth’s), for a deficiency of $155,-707.78 in income tax and an addition to tax of $38,927.20 under section 6651(a), I.E.C. 1954,1 for Garth’s taxable period ended May 31, 1962.
The issues for our decision herein are as follows: (1) Whether Garth’s flocks of laying hens were properly includable in inventory; if so, (2) whether Garth’s use of the farm-price method of valuing its pullet and laying-hen flock inventories clearly…
2Cases cited10 opinions
- Brown v. HelveringSupreme Court of the United States · 1934
- Commissioner v. HansenSupreme Court of the United States · 1959
- United States v. CattoSupreme Court of the United States · 1966
- Jud Plumbing & Heating, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
- Patchen v. CommissionerUnited States Tax Court · 1956
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- Auburn Packing Co. v. CommissionerUnited States Tax Court · 1973
- Bay State Gas Co. v. CommissionerUnited States Tax Court · 1980
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