Epic Metals v. Commissioner
United States Tax Court
S, a corporation, primarily sold products manufactured by M, a manufacturing corporation. S was the wholly owned subsidiary of M. S reported its income for Federal tax purposes on the cash method of accounting; M reported its income on the accrual method. The Commissioner determined that S was required by secs. 446 and 471, I.R.C. 1954, and the regulations promulgated thereunder to maintain inventories and to use the accrual method of accounting.
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S, a corporation, primarily sold products manufactured by M, a manufacturing corporation. S was the wholly owned subsidiary of M. S reported its income for Federal tax purposes on the cash method of accounting; M reported its income on the accrual method. The Commissioner determined that S was required by secs. 446 and 471, I.R.C. 1954, and the regulations promulgated thereunder to maintain inventories and to use the accrual method of accounting. Held, S is required to maintain inventories and to use the accrual method of accounting since its sales of the products were a material…
1Opinion of the Court
EPIC METALS CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Epic Metals v. Commissioner
Docket No. 2689-79.
United States Tax Court
T.C. Memo 1984-322; 1984 Tax Ct. Memo LEXIS 351; 48 T.C.M. (CCH) 357; T.C.M. (RIA) 84322;
June 25, 1984.
S, a corporation, primarily sold products manufactured by M, a manufacturing corporation. S was the wholly owned subsidiary of M. S reported its income for Federal tax purposes on the cash method of accounting; M reported its income on the accrual method. The Commissioner determined that S was required by secs. 446 and 471,…
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