- 5 - The primary issue in Richardson I was whether Investments “properly adopted the use of a single LIFO inventory pool in computing inventory values pursuant to the dollar-value, link- chain LIFO method”. Id. at 737. Investments argued that it was entitled to use a single pool for new cars and new trucks, and the Commissioner argued that each model line3 should constitute a separate dollar-value pool. Id. at 745. The Court rejected Investments’ method of utilizing a single pool for new cars and new trucks, and it rejected the Commissioner's single pool per model line argument. Id. at 747. Rather, the Court held that “new cars and new trucks should be placed in separate pools.” Id. at 748. After the opinion in Richardson I was filed (May 11, 1981), Investments recomputed its taxable year 1974 LIFO inventory calculation, placing new cars and new trucks in separate pools. The calculation was submitted to the Court under the Court’s Rule 155 procedure, and a decision was entered. Investments and the Commissioner reached an agreement on Investments’ inventory calculations for taxable years 1975, 1976, and 1977, conforming those calculations to the decision in Richardson I. For taxable years 1978, 1979, and 1980, Investments amended its tax returns to conform its inventory calculations to the decision in Richardson I. 3 The parties have stipulated that vehicle “model lines” are the different vehicle product lines offered by the manufacturers; for example, Ford Motor Co. offers the Mustang model line, the Escort model line, etc.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011