E.W. Richardson - Page 25

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          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’s                   






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