E.W. Richardson - Page 4

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          and Richardson Properties.  In 1986, the subsidiaries were                  
          liquidated into Investments and thereafter operated as divisions            
          of Investments.  During the years at issue, Investments, through            
          its Rich Ford Sales division, operated a franchised Ford Motor              
          Co. (Ford) automobile and truck dealership in Albuquerque, New              
          Mexico, and also held franchises for the sale of Daihatsu                   
          automobiles and Daihatsu and Isuzu trucks.                                  
               Prior to the taxable year 1974, Investments valued its new             
          car and new truck inventory on the specific identification, lower           
          of cost or market, first-in, first-out (FIFO) method.  With its             
          Federal income tax return for the taxable year 1974, Investments            
          filed Form 970, Application to Use LIFO Inventory Method, the               
          Commissioner electing to use the last-in, first-out (LIFO) method           
          of valuing its inventory.  Specifically, Investments elected to             
          use the dollar-value, link-chain, earliest-acquisition method of            
          inventory valuation with a single LIFO inventory pool for both              
          its new cars and new trucks.2                                               
               Investments’ 1974 Federal corporate income tax return was              
          audited by the Commissioner.  As a result of that audit, the                
          Commissioner issued a notice of deficiency.  The adjustments in             
          the notice of deficiency were redetermined by this Court in                 
          Richardson Invs., Inc. v. Commissioner, 76 T.C. 736 (1981)                  
          (Richardson I).                                                             

          2    Although Investments checked the “double-extension method”             
          block on its Form 970, respondent concedes that petitioner duly             
          elected the link-chain method of computing the last-in, first-out           
          (LIFO) value of its inventory.                                              



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