E.W. Richardson - Page 16

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          equivalent; i.e., base-year cost.  1 Schneider, Federal Income              
          Taxation of Inventories, sec. 14.01[1], at 14-4, 14-5 (1996).               
               The regulations contain four alternative approaches to                 
          determine base-year cost:  The double-extension method, the index           
          method, the link-chain method, and the retail method.  Sec.                 
          1.472-8(e)(1), Income Tax Regs.  Investments used the “link-                
          chain” method of computing the base-year cost of the inventory in           
          its LIFO pools.6                                                            
               More specifically, Investments used the link-chain, dual-              
          index method for the determination of quantity changes and for              
          the valuation of increments in its LIFO pools.  Under the dual-             
          index method, a cumulative deflator index is used to value ending           
          inventory at base-year cost, and a layer-valuation index is used            
          to value increments in the pool.                                            
               Each year Investments calculates an annual and a cumulative            
          deflator index for each pool in order to convert current year               
          ending inventory at “actual cost”7 to what it would be at base-             


          6    Although the regulations do not contain a specific                     
          description of the link-chain methodology, or an example of such            
          methodology, the parties have stipulated that Investments’ link-            
          chain methodology, as described below, was appropriate.  For a              
          more detailed description of the link-chain methodology, see Rev.           
          Proc. 92-79, sec. 4, 1992-2 C.B. 457, 460 (describing alternative           
          LIFO method for automobile dealers); see also 1 Schneider,                  
          Federal Income Taxation of Inventories, sec. 14.02[3][b], at 14-            
          96 (1996).                                                                  
          7    In arriving at the actual cost of its ending inventory in              
          its new car and new truck pools each year, Investments uses the             
          actual invoice cost of each vehicle in inventory.                           




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