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ROCKWELL INTERN. CORP. v. C.I.R.

No. 82-3046.

694 F.2d 60 (1982)

ROCKWELL INTERNATIONAL CORPORATION, Appellant, v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

Decided November 29, 1982.

As Amended December 2, 1982.

Attorney(s) appearing for the Case

Richard A. Mullens (argued), Robert E. Liles, II, Silverstein & Mullens, Washington, D.C., for appellant.

Michael L. Paup, Ernest J. Brown (argued), U.S. Dept. of Justice, Tax Div., Washington, D.C., for appellee.

Before SEITZ, Chief Judge, ROSENN and GARTH, Circuit Judges.

OPINION OF THE COURT

PER CURIAM.

I.

Rockwell International Corp. (taxpayer) appeals from the Tax Court's denial of its petition to redetermine a tax deficiency and argues that it was an abuse of discretion for the Commissioner of Internal Revenue to disallow a $16,250,000 writedown in inventory held under a fixed-price contract. Taxpayer computed this writedown pursuant to its method of inventory accounting, which it claims is acceptable under...

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