Appeal of Orents Department Stores, Inc.

Board of Tax Appeals

Appeal of Orents Department Stores, Inc.

3 B.T.A. 52

CourtUnited States Board of Tax Appeals

DecidedNovember 16, 1925

DocketDocket No. 2400

StatusPublished

Cited by3 cases

This text of 3 B.T.A. 52 (Appeal of Orents Department Stores, Inc.) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Appeal of Orents Department Stores, Inc., 3 B.T.A. 52 (bta 1925).

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Opinion

[53]*53OPINION.

Trammell:

The taxpayer took its closing inventory for 1918 on the basis of cost and undertook to reduce it to an alleged market by a straight reduction of 10 per cent with respect to certain goods which were claimed to have been shopworn or out of style. The Commissioner properly disallowed such a reduction. The disallowance of such a reduction in inventory for the close of 1918, if the Commissioner accepted a similar reduction in the closing inventory for the previous year which was the opening inventory for the taxable year, would cause an unwarranted shifting of income. But we have no evidence as to 'what action was taken by the Commissioner for the opening inventory for 1918, and we therefore approve his action in disallowing the reduction in the closing inventory.

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[53]*53OPINION.

Trammell:

The taxpayer took its closing inventory for 1918 on the basis of cost and undertook to reduce it to an alleged market by a straight reduction of 10 per cent with respect to certain goods which were claimed to have been shopworn or out of style. The Commissioner properly disallowed such a reduction. The disallowance of such a reduction in inventory for the close of 1918, if the Commissioner accepted a similar reduction in the closing inventory for the previous year which was the opening inventory for the taxable year, would cause an unwarranted shifting of income. But we have no evidence as to 'what action was taken by the Commissioner for the opening inventory for 1918, and we therefore approve his action in disallowing the reduction in the closing inventory.

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3 B.T.A. 52, Counsel Stack Legal Research, https://law.counselstack.com/opinion/appeal-of-orents-department-stores-inc-bta-1925.

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