- 19 - petitioners purchased and set out in their scrap yard for the purpose of attracting wild cats to deter snakes and rats. Cost of Goods Sold Petitioners contend that in 1995 Columbia had cost of goods sold of $18,742, computed as follows: Opening Inventory $1,500 Add: Purchases 18,742 Less: Closing Inventory 1,500 Cost of Goods Sold $18,742 On brief, respondent concedes that petitioners have substantiated purchases in the amount of $18,742 but contends that petitioners have not established the value of their opening or ending inventory, and thus are not entitled to reduce Columbia’s gross receipts for cost of goods sold. We agree with respondent. In a manufacturing, merchandising, or mining business, gross income means total sales less the cost of goods sold. Sec. 1.61- 3(a), Income Tax. Regs. Cost of goods sold is computed by subtracting the value of ending inventory (goods still on hand at the end of the year) from the sum of the opening inventory and purchases during the year. Primo Pants Co. v. Commissioner, 78 T.C. 705, 723 (1982). On their 1995 Federal income tax return, petitioners claimed to have used the lower of cost or market as the basis for valuing their inventory. Under this approach, “the market value of eachPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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