Progressive Plastics, Inc. v. Testa

In this appeal, Progressive Plastics, Inc. (PPI) challenged the tax commissioner's decision to increase PPI's personal property tax assessments for 2004 and 2005. In amending the assessments, the commissioner recomputed the value of PPI's inventory based on the FIFO (first in, first out) accounting method rather than the LIFO (last in, first out) method, which PPI had used on its books. The board of tax appeals (BTA) affirmed the commissioner's amended assessments, finding that collateral estoppel barred PPI's FIFO/LIFO claim on the grounds that the issue had already been litigated and decided against PPI in the tax-year 2003 proceedings. The Supreme Court reversed, holding (1) the BTA incorrectly determined that collateral estoppel applied to PPI's appeal for the 2004 and 2005 tax years; and (2) the BTA erred by upholding the commissioner's assessments at issue here, as the substitution of FIFO for LIFO was impermissible under the circumstances of this case. View "Progressive Plastics, Inc. v. Testa" on Justia Law