Legal Opinion

Little v. Commissioner

United States Tax Court

Decided May 6, 1960No. Docket No. 61201Published

1. Sale of Culls From Breeding Herd -- Inventory -- Basis -- Eliminated From Opening Inventory. -- Petitioners used a unit-livestock-price method of inventorying their livestock, including that held for breeding purposes.

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1. Sale of Culls From Breeding Herd -- Inventory -- Basis -- Eliminated From Opening Inventory. -- Petitioners used a unit-livestock-price method of inventorying their livestock, including that held for breeding purposes. They must eliminate the inventory basis of breeding culls from opening inventory when culls are sold and long-term capital gain under section 117(j) is computed. 2. Net Operating Loss Deduction -- Reduction of Net Operating Loss Carryback by 50 Per Cent of Capital Gains of the Tax Year -- Sec. 122(c). -- Section 122(c) of the 1939 Code requires that a net operating loss…

1Opinion of the Court

Andrew Little, Jr., and Myrn H. Little, Petitioners, v. Commissioner of Internal Revenue, Respondent

Little v. Commissioner

Docket No. 61201

United States Tax Court

34 T.C. 156; 1960 U.S. Tax Ct. LEXIS 160;

May 6, 1960, Filed

Decision will be entered that there is a deficiency of $ 10,866.62 in the petitioners' income tax for 1951.

1. Sale of Culls From Breeding Herd -- Inventory -- Basis -- Eliminated From Opening Inventory. -- Petitioners used a unit-livestock-price method of inventorying their livestock, including that held for breeding purposes. They must eliminate the inventory basis of…

2Cases cited1 opinion

  1. Little v. CommissionerUnited States Tax Court · 1960

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