LITTLE v. C. I. R.

No. 17185.

294 F.2d 661 (1961)

Andrew LITTLE, Jr., and Myrn Little, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

July 7, 1961.


Attorney(s) appearing for the Case

Bellwood & Goodman, Sherman J. Bellwood, Rupert, Idaho, for petitioner.

Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Melva M. Graney and Carolyn R. Just, Attys., Dept. of Justice, Washington, D. C., for respondent.

Stephen H. Hart, Claude M. Maer, Jr., Denver, Colo., for Nat'l Livestock Tax Com., as amicus curiae.

Before BARNES, HAMLIN and MERRILL, Circuit Judges.


MERRILL, Circuit Judge.

This petition for review of a tax court decision presents a problem of concern to the livestock industry: the proper income tax treatment of the proceeds of sale of breeding stock raised by the taxpayers where the taxpayers are on the accrual system of accounting and following the "unit-livestock-price method" of livestock inventory valuation.

Taxpayers contend that they are entitled to change their breeding herd from an accrual to...

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