- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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