Mountain State Ford Truck Sales, Inc., E.P. O'Meara, Tax Matters Person - Page 24




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          in section 472(b)(2) and the regulation thereunder.  Section                
          472(b)(2) provides:                                                         
                    (b) Method Applicable.--In inventorying goods                     
               specified in the application described in subsection                   
               (a), the taxpayer shall:                                               
                         *    *    *    *    *    *    *                              
                         (2) Inventory them at cost * * *                             
          The regulation under section 472(b)(2), section 1.472-2(b),                 
          Income Tax Regs., provides:                                                 
                    (b) The inventory shall be taken at cost regard-                  
               less of market value.                                                  
               Both parties rely in part on dictionary definitions of the             
          word "cost" to support their divergent positions regarding the              
          meaning of the term "cost" in section 472(b)(2) and the regula-             
          tion thereunder.  According to respondent, the commonly under-              
          stood and generally accepted meaning of the word "cost", as                 
          reflected in dictionary definitions, is actual cost.  According             
          to petitioner, dictionary definitions of the word "cost" "clearly           
          encompass replacement cost."   We agree with respondent.                    
               Black's Law Dictionary 345 (6th ed. 1990) defines the word             
          "cost" to mean:  "Expense; price.  The sum or equivalent ex-                
          pended, paid or charged for something.  See also Actual cost;               
          Costs; Net cost; Rate."  Merriam-Webster's Collegiate Dictionary            
          262 (10th ed. 1996) defines the word "cost" to include:  "The               
          amount or equivalent paid or charged for something:  price."                
          Webster's Third New International Dictionary 515 (1993 ed.)                 
          defines the word "cost" to include:  "the amount or equivalent              


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