From our private database of 39,700+ case briefs...
Willamette Industries, Inc. v. Commissioner
United States Tax Court
118 T.C. 126 (2002)
Willamette Industries, Inc. (Willamette) (plaintiff) grew, harvested, and processed trees for commercial sale and use. Willamette’s business required the trees to reach maturity before they were harvested and processed. Some of Willamette’s trees were damaged by insects and bad weather before reaching maturity. Willamette prematurely harvested the damaged trees. Instead of selling the harvested trees in their unprocessed condition, Willamette processed the trees and sold the resulting products as if the trees had been mature. Willamette regarded the trees’ damage, processing, and sale as an involuntary conversion under § 1033 of the federal tax code. Willamette contended that § 1033 allowed it to defer some of its taxable gain on the processing and sale of the damaged trees. The commissioner of internal revenue (commissioner) (defendant) determined that there had been no involuntary conversion under § 1033, because Willamette had processed and sold the damaged trees as usual rather than selling the trees in an unprocessed condition. Willamette petitioned the tax court for a redetermination.
Rule of Law
Holding and Reasoning (Gerber, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 645,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 645,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 39,700 briefs, keyed to 988 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.