- 2 -
2. Held, further, I’s method of accounting for
its new car and new truck inventories did not clearly
reflect income, as I inconsistently defined its items
of inventory for both its new car and new truck pools.
Sec. 446(b), I.R.C.; secs. 1.471-2(b), 1.472-8(a),
Income Tax Regs.
3. Held, further, R did not abuse her discretion
in determining that I must define its items of
inventory for its new car and new truck LIFO pools by
model code. Sec. 446(b), I.R.C.
4. Held, further, the expenses I incurred in
owning and operating its airplane during the years at
issue are allowable under sec. 162, I.R.C.
Patricia Tucker, for petitioner.
Thomas F. Eagan, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge: Respondent determined deficiencies in,
additions to, and a penalty on petitioner’s Federal income tax
for taxable years 1988 and 1989 as follows:
Additions to Tax and Penalty
Sec. Sec. Sec.
Year Deficiency 6653(a)(1) 6661 6662(a)
1988 $656,486 $11,971 $5,704 -0-
1989 323,343 -0- -0- $34,003
All section references are to the Internal Revenue Code in
effect for the taxable years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated.
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