 | United States. Tax Court - 1979 - 1352 pages
...abused his discretion in determining that petitioner's method should be changed. As was pointed out by the Supreme Court in Thor Power Tool Co. v. Commissioner, 439 US 522 (1979), affg. 64 TC 154 (1975): In construing sec. 446 and its predecessors, the Court has held that "[t]he... | |
 | United States. Tax Court - 1986 - 1142 pages
...Pacific Car & Foundry Co. 76.639 411 0.5 3,034,130 733,743 24.2 After the promulgation of the decision of the Supreme Court in Thor Power Tool Co. v. Commissioner, 439 US 522 (1979), SAJAC published and distributed a brochure entitled "The SAJAC System and the Internal Revenue Code."... | |
 | United States. Congress. Joint Committee on Taxation - 1979 - 1570 pages
...Relating to Inventory Writedowns Revenue Procedure 80-5 and Revenue Ruling 80-60 require taxpay»r~ to conform their method of inventory accounting to...Commissioner, 439 US 522 (1979). For taxpayers with ric** inventories (inventories in excess of foreseeable demand) that iuve been erroneously written... | |
 | United States. Congress. Joint Committee on Taxation - 1980 - 28 pages
...accounting to that method of inventory accounting approved by the Supreme Court in Thor Power Tool v. Commissioner, 439 US 522 (1979). For taxpayers...pronouncements require that the writedowns be taken into income. These Internal Revenue Service pronouncements, which were issued on February 8, 1980,... | |
 | United States. Tax Court - 1980 - 892 pages
...consistently from year to year. In interpreting the above-quoted statutory and regulatory language, the Supreme Court, in Thor Power Tool Co. v. Commissioner, 439 US 522 (1979), stated (p. 540): Most importantly, the Code and Regulations give the Commissioner broad discretion... | |
 | United States. Congress. Senate. Committee on Finance - 1983 - 54 pages
...Government in a particular case. Security Flour Mills Co. v. Commissioner, 321 US 281, 285-87 (1944). The Supreme Court in Thor Power Tool Co. v. Commissioner, 439 US 522, 43 AFTR 2d 79-362 (1979), where the Court disallowed an inventory write-down to an estimated market... | |
 | United States. Congress. House. Committee on Ways and Means - 1986 - 996 pages
...six years. Used for over forty years, this formula is utilized in Rev. Proc. 85-8 and was endorsed by the Supreme Court in Thor Power Tool Co. v. Commissioner, 439 US 522 (1979). Many taxpayers with short-term trade receivables, particularly those with a high volume of small dollar... | |
 | Thomas A. King - 2006 - 1 pages
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Ruling 80-60 require taxpayers to conform their method of inventory accounting to that method of inventory accounting approved by the Supreme Court in Thor Power Tool Co. v. Commissioner, 439 US 522 (1979). For taxpayers with... 