Income Tax Issues
Costs of Goods Sold (COGS)

Lord v. Commissioner
T.C. Memo. 2022-14

On March 1, 2022, the Tax Court issued a Memorandum Opinion in the case of Lord v. Commissioner (T.C. Memo. 2022-14). The primary issue presented in Lord was whether the tax depreciation methods for inventory production assets can be used under either section 263A or section 471 when section 280E is applied. Holding: In a battle of Lord versus the IRS, one would think the almighty would prevail. Turns out, not so. Background to Lord

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Scott St. Amand May 23, 2022
Income Tax Issues
Costs of Goods Sold (COGS)

BRC Operating Company LLC v. Commissioner
T.C. Memo. 2021-59

On May 12, 2021, the Tax Court issued a Memorandum Opinion in the case of BRC Operating Company LLC v. Commissioner (T.C. Memo. 2021-59). The primary issue presented in BRC Operating Company LLC v. Commissioner was whether and when a cost of goods sold (COGS) offset may be recognized for tax purposes. Background to BRC Operating Company LLC v. Commissioner During tax years 2008 and 2009 the petitioner paid approximately $180 million to acquire hundreds of

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Scott St. Amand May 12, 2021
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Lord v. Commissioner
T.C. Memo. 2022-14

On March 1, 2022, the Tax Court issued a Memorandum Opinion in the case of Lord v. Commissioner (T.C. Memo. 2022-14). The primary issue presented in Lord was whether the tax depreciation methods for inventory production assets can be used under either section 263A or section 471 when section 280E

Read More »
Scott St. Amand May 23, 2022

BRC Operating Company LLC v. Commissioner
T.C. Memo. 2021-59

On May 12, 2021, the Tax Court issued a Memorandum Opinion in the case of BRC Operating Company LLC v. Commissioner (T.C. Memo. 2021-59). The primary issue presented in BRC Operating Company LLC v. Commissioner was whether and when a cost of goods sold (COGS) offset may be recognized for tax

Read More »
Scott St. Amand May 12, 2021