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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.
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