- 25 - Prods. Co. v. Commissioner, supra at 739-740; Wendle Ford Sales, Inc. v. Commissioner, supra at 459. Petitioner next argues that, even if a change in the treatment of an item is found to have occurred in taxable year 1981, the change does not rise to the level of a change in method of accounting because such change was merely a change in valuation. In support of this argument, petitioner relies on the regulatory exception for a change in underlying facts, section 1.446-1(e)(2)(ii)(b), Income Tax Regs, and the case of Baltimore & O.R.R. v. United States, 221 Ct. Cl. 16, 603 F.2d 165 (1979). In Baltimore & O.R.R., the court found that the taxpayer had not changed its method of accounting by changing to a valuation formula that more accurately estimated salvage value, finding that such a change was merely a change in underlying fact. Id. at 168-169. The objective of inventory accounting is to value inventories. All-Steel Equip. Inc. v. Commissioner, 54 T.C. 1749, 1757 (1970), affd. in part and revd. in part 467 F.2d 1184 (7th Cir. 1972); see Fox Chevrolet, Inc. v. Commissioner, 76 T.C. at 722. Accordingly, any change in inventory accounting can be characterized as a change in valuation. Thus, under petitioner’s argument, any change in inventory accounting could be characterized as a change in underlying fact and, therefore, not a change in method of accounting. We reject petitioner’sPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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