First Nat'l Bank v. Commissioner
United States Tax Court
For its taxable year ending Oct. 31, 1977, a year not before the Court, Hall Paving filed a Form 970, application to use LIFO inventory method. Pursuant to said election, the LIFO method was to be applied to "All inventory of stone." For its taxable year ending Oct. 31, 1979, Hall Paving wrote down the inventory value of soil aggregate based on a reduction in the soil aggregate's market value.
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For its taxable year ending Oct. 31, 1977, a year not before the Court, Hall Paving filed a Form 970, application to use LIFO inventory method. Pursuant to said election, the LIFO method was to be applied to "All inventory of stone." For its taxable year ending Oct. 31, 1979, Hall Paving wrote down the inventory value of soil aggregate based on a reduction in the soil aggregate's market value. Held, Hall Paving's soil aggregate was included within its election to adopt the LIFO inventory method. Held, further, Hall Paving's writedown of soil aggregate constitutes a change in accounting method…
1Opinion of the Court
WHITAKER, Judge:
Respondent determined petitioners to be hable, as transferees, for deficiencies in Federal income tax of Hall Paving Co., Inc., Transferor (Hall Paving), for the years and in the amounts indicated:
TYE Oct. 31-Deficiency2
1978 ••• $197.04
1979 ••• 90,087.75
After concessions by petitioners, the issues presented for consideration are:(1) Whether Hall Paving’s inventory of soil aggregate was included within its election to adopt the Last-In, First-Out (LIFO) inventory method;(2) Whether Hall Paving’s writedown of soil aggregate constituted a change in accounting method;(3) Whether…
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