Legal Opinion

Consolidated Mfg. v. Commissioner

United States Tax Court

Decided July 20, 1998No. Tax Ct. Dkt. No. 6176-96PublishedCited by 5 opinions

Company C (C), an automobile parts remanufacturer required to take inventories pursuant to sec. 471, 1Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect for the years at issue.

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Company C (C), an automobile parts remanufacturer required to take inventories pursuant to sec. 471, 1Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. elected under sec. 472 to apply the last-in, first-out (LIFO) inventory method of accounting with respect to certain raw materials (raw materials one), labor, and overhead included in its inventories, but not with respect to certain other raw materials (raw materials two) included therein as to…

1Opinion of the Court

Chiechi, Judge:

Respondent determined the following S corporation adjustments to the ordinary, distributable net, or taxable income of Consolidated Manufacturing, Inc. (Consolidated):

Year Taxable income

1990 . $3,730,862

1991 . 123,596

The issues remaining for decision are:(1) Did respondent abuse respondent’s discretion in determining that Consolidated’s method of reporting certain raw materials, labor, and overhead on the LIFO inventory method and certain other raw materials on the FIFO inventory method does not clearly reflect income because it contravenes the requirements of section 4721 and…

2Cases cited19 opinions

  1. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  2. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
  3. Lemmen v. CommissionerUnited States Tax Court · 1981
  4. Kanawha Gas & Utilities Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1954
  5. Fox Chevrolet, Inc. (Maryland) v. CommissionerUnited States Tax Court · 1981

14 more not listed; retrieve them via the Exa API.

3Cited by5 opinions

  1. Mountain State Ford Truck Sales, Inc. v. CommissionerUnited States Tax Court · 1999
  2. Consolidated Manufacturing, Inc., M. P. Long Living Trust, Merl Philip Long, Trustee, Tax Matters Person v. CommissionerUnited States Tax Court · 1998
  3. Consolidated Mfg. v. CommissionerUnited States Tax Court · 1998
  4. Mountain State Ford Truck Sales, Inc. v. CommissionerUnited States Tax Court · 1999
  5. Mountain State Ford Truck Sales, Inc., E.P. O'Meara, Tax Matters Person v. CommissionerUnited States Tax Court · 1999

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