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United States v. Ingredient Technology Corp.
Citation:
698 F.2d 88 (1983)Facts
Ingredient Technology Corporation (ITC) was a distributor of food additives and chemicals. In December 1974, as the end of ITC’s tax year approached, executives devised a plan to reduce the company’s taxable income. They arranged to “sell” approximately $1.8 million worth of inventory to European customers, shipping the goods to a public warehouse in New Jersey. These transactions were documented as sales with “bill and hold” arrangements, where the customers supposedly purchased the goods but requested ITC to hold them for later delivery. However, immediately after the new tax year began, ITC retrieved the goods from the warehouse and returned them to inventory. Evidence showed that the customers had never actually ordered the goods, the transactions lacked genuine purchase orders, and the entire scheme was designed solely to temporarily reduce year-end inventory and thus taxable income.
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