E.W. Richardson - Page 7

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          otherwise request respondent’s consent to change its LIFO                   
          inventory valuation method.                                                 
               In its new truck pool for years 1979 through 1985,                     
          Investments treated all of its vans (E series) and extended body            
          vans (S series) as one inventory unit, but separated its full-              
          size pickups (F series), extended cab full-size pickups (X                  
          series), and four-door full-size pickups (W series) into three              
          different inventory units by load-carrying ability (i.e., 1/2-              
          ton, 3/4-ton, and 1-ton).                                                   
               For 1986, 1987, and 1988, Investments treated all of its               
          full-size pickups (the F, X, and W series) as one inventory unit            
          and all of its vans (E series) and extended body vans (S series)            
          as another inventory unit.  For 1989, Investments treated each of           
          its E series vans, its S series vans, its F series pickups, its W           
          series pickups, and its X series pickups as separate inventory              
          units.                                                                      
               For its Ranger trucks (R series) and Aerostar vans (A                  
          series), Investments always treated each of those model lines as            
          one inventory unit, regardless of any submodels that were                   
          introduced; but it always separated its Bronco trucks (U series)            
          by size; i.e., the full-size model (U15) and the Bronco II models           
          (U12 and U14).                                                              
               In addition to operating its automobile dealership through             
          its Rich Ford Sales division, Investments, among other things,              
          provided management consulting services to its operating                    




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