- 16 - 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.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011