Buck

Petitioners seek review of a decision of the Board of Tax Appeals which determined that there were deficiencies in the ' income taxes of Industrial Solvents Corporation (hereinafter called the taxpayer) for the fiscal years ending November 30, 1927, 1928, and 1929, and sustained proposed assessments thereof against petitioners as transferees of the taxpayer. That petitioners are such transferees and, as such, liable for any tax deficiency properly chargeable to the taxpayer, is not questioned in this court. • The question here is whether there was any such deficiency.

The taxpayer was engaged in the manufacture and sale of industrial alcohol. The alcohol was sold and delivered in steel drums. The cost of the drums to the taxpayer was between $4 and $4.25 each. The average life of a drum was about four years. The taxpayer maintained an inventory of all drums on hand, including those in the possession of its customers. Their total number averaged between 8,000 and 9,000 during each of the years in question. In its income tax return for each of those years the taxpayer treated as its property, used in its trade or business, all the drums so inventoried, whether in its hands or in…