E.W. Richardson - Page 18

                                       - 18 -                                         
          there is an increment in inventory.  See id.  The LIFO value of             
          such increment is then computed, see id., and the increment is              
          added to beginning inventory for the pool to determine the                  
          current year’s LIFO ending inventory for the pool, see id.; see             
          also Fox Chevrolet, Inc. v. Commissioner, 76 T.C. at 733 n.16.              
               If ending inventory valued at base-year cost is less than              
          beginning inventory at base-year cost, there is a decrement in              
          inventory.  See sec. 1.472-8(e)(2)(iv), Income Tax Regs.  When              
          there is decrement, the current year’s LIFO ending inventory is             
          the beginning inventory reduced by the decrement.  See id.                  
               Once the total LIFO ending inventory is calculated, the                
          ending inventory figure is subtracted from the sum of the values            
          for beginning inventory and purchases during the year to produce            
          the COGS for the current year.  Fox Chevrolet, Inc. v.                      
          Commissioner, supra at 722.                                                 
               B. Unauthorized Change in Method of Accounting                         
               Respondent determined that Investments made an unauthorized            
          change in method of accounting when it changed the definition of            
          its inventory units for its new car pool from model code10 to               


          10   The parties have stipulated that vehicle "model code" is               
          synonymous with vehicle "body style".  For the remainder of the             
          opinion, we will use model code to refer to both model code and             
          body style.  Furthermore, the parties have stipulated that a                
          vehicle model code is a code given to each vehicle by the                   
          manufacturer that differentiates the different body                         
          configurations and interior styling packages of vehicles within             
          each model line (e.g., a two-door sports model, a four-door sedan           
          with standard interior, etc.).                                              




Page:  Previous  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  Next

Last modified: May 25, 2011