- 22 - Thor Power Tool Co. v. Commissioner, 439 U.S. 522, 532 (1979). Sections 1.471-1 and 1.471-2, Income Tax Regs., provide general guidance for determining the timing of inventory adjustments in order to satisfy the requirements of section 471. Thus, as a general matter, the seller must remove an item from inventory when title passes to the purchaser. If the item is returned, it is included in inventory for the year of return. When a taxpayer elects to exclude sales revenue attributable to an item under the section 458 election, removing the item from inventory and deducting its cost would not be consistent with the requirements of section 471. First, such treatment would deviate from generally accepted accounting principles. Under these principles, sales with right of return are accounted for by symmetrical reductions in both the sales account and the cost of goods sold adjustment account to reflect estimates of future returns. See SFAS No. 48 (June 1981); Jarnagin, Financial Accounting Standards 610-612 (16th ed. 1994); Kay & Searfoss, Handbook of Accounting and Auditing 13-11 to 13-12 (2d ed. 1989). Second, the mismatching of income and expense would not clearly reflect income. Petitioners' argument requires us to assume that Congress intended a result that would have conflicted with section 471. Thus, it was not in reliance on general inventory accounting principles that Congress omitted to provide for the cost deduction that petitioners believe Congress intended. On the other hand, if it was Congress' intention to create anPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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