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contained in Columbia’s 1995 ending inventory, were sold to third
parties in 1996 for $23,400.
In sum, petitioners have failed to show that the market
value of Columbia’s 1995 ending inventory was less than its
$21,192 cost.
We conclude and hold that Columbia’s 1995 cost of goods sold
was zero, computed as $0 (opening inventory) plus $21,192
(purchases) minus $21,192 (ending inventory). Accordingly,
respondent’s determination on this issue is sustained.
All other contentions raised by the parties are irrelevant,
without merit, or moot.
To reflect the foregoing and concessions of the parties,
Decision will be entered
Under Rule 155.
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