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WILLAMETTE INDUSTRIES, INC. v. C.I.R.

Nos. 97-70033 to 97-70035.

149 F.3d 1057 (1998)

WILLAMETTE INDUSTRIES, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided July 28, 1998.

Attorney(s) appearing for the Case

Charles P. Duffy, Philip N. Jones, and Peter J. Duffy, Duffy, Kekel, Jones & Bernard, Portland, Oregon, for petitioner-appellant.

Loretta C. Argett, Richard Farber, and John A. Dudeck, Jr., United States Department of Justice, Tax Division, Washington, DC, for respondent-appellee.

Before: ALARCON, FERGUSON, and BRUNETTI, Circuit Judges.

PER CURIAM:

The Commissioner determined deficiencies in income taxes for Willamette Industries, Inc. ("Willamette") for the years 1978-1983. Willamette challenges the tax court's rulings on two separate issues in connection with these deficiencies: (1) whether, for purposes of 26 U.S.C. § 631(a)1, the fair market value of timber logged by Willamette and its subsidiaries on United States Forest Service lands includes the price of building...

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