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intention that they should be otherwise construed.12 See supra
note 8. Inventory is, simply stated, property that is held for
sale. Grant Oil Tool Co. v. United States, 108 Ct. Cl. 620, 381
F.2d 389, 397 (1967).
We have found that the emulsified asphalt is not merchandise
held for sale by petitioner in the operation of petitioner's
service business, and that petitioner does not keep any raw
materials or finished goods on hand. Previously, the Court of
Appeals for the Second Circuit considered the fact that the
taxpayer had no stock or merchandise on hand and no warehouse or
storeroom for merchandise, and that goods were delivered directly
from the manufacturer to the customer, to be conclusive in
finding that the taxpayer did not maintain inventories. See
Simon v. Commissioner, 176 F.2d 230, 232 (2d Cir. 1949) (buyer
12 "Inventory" is defined in The Random House College
Dictionary (1982) as:
1. a detailed, often descriptive, list of articles, giving
the code number, quantity, and value of each; catalog. * * *
3. a complete listing of merchandise or stock on hand, raw
materials, etc., made each year by a business concern. 4.
the objects or items represented on such a list, as a
merchant's stock of goods. 5. their aggregate value.
Similarly, "inventory" is defined in Webster's Second New
International Dictionary (1957) as:
1. an account, catalog, or schedule, made by an executor or
administrator, of all the goods and chattels, and sometimes
of the real estate, of a deceased person; a list of the
property of a person or estate; hence an itemized list of
goods or valuables, with their estimated worth; specif., the
annual account of stock taken in any business; * * * 2.
Inventoriable goods, hence stock of such; * * * .
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