Miller, Daybill & Co. v. Commissioner

Board of Tax Appeals

Miller, Daybill & Co. v. Commissioner

15 B.T.A. 13, 1929 BTA LEXIS 2935

United States Board of Tax Appeals·Decided January 23, 1929·No. Docket No. 20267.·Published·Cited by 1 cases

Opinion

[15] OPINION.

Smith :

In computing petitioner’s tax liability for the year 1920 the Commissioner increased net income by adding to the closing lumber inventory an arbitrary amount based upon the ratio of purchases to amounts charged off to depreciation over several preceding and subsequent years.

Upon consideration of the entire record we are of the opinion that petitioner’s inventory for the taxable year 1920 clearly reflected its income and that the Commissioner’s adjustment thereof was error.

iJudgment will be entered wider Bule 50.

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[15] OPINION.

Smith :

In computing petitioner’s tax liability for the year 1920 the Commissioner increased net income by adding to the closing lumber inventory an arbitrary amount based upon the ratio of purchases to amounts charged off to depreciation over several preceding and subsequent years.

Upon consideration of the entire record we are of the opinion that petitioner’s inventory for the taxable year 1920 clearly reflected its income and that the Commissioner’s adjustment thereof was error.

iJudgment will be entered wider Bule 50.

Miller, Daybill & Co. v. Commissioner, 15 B.T.A. 13, 1929 BTA LEXIS 2935 (bta 1929).

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Opinion

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