- 31 - (1) It must conform as nearly as may be to the best accounting practice in the trade or business, and (2) It must clearly reflect the income. [Sec. 1.471- 2(a), Income Tax Regs.] Furthermore, the regulations provide that, in order to clearly reflect income: the inventory practice of a taxpayer should be consistent from year to year, and greater weight is to be given to consistency than to any particular method of inventorying or basis of valuation * * * [Sec. 1.471-2(b), Income Tax Regs.] In addition, the regulations addressing dollar-value LIFO provide: Any taxpayer may elect to determine the cost of his LIFO inventories under the so-called “dollar-value” LIFO method, provided such method is used consistently and clearly reflects the income of the taxpayer * * * [Sec. 1.472-8(a), Income Tax Regs.] The foregoing regulations unequivocally indicate that consistent application of a method of accounting is necessary for the method to clearly reflect income. Sec. 446(b); secs. 1.471- 2(b), 1.472-8(a), Income Tax Regs. Accordingly, if a method of inventory accounting is not consistently applied, this fact alone may cause the method not to clearly reflect income. Our case law has also recognized the significance of the consistency requirement when examining whether a method of accounting clearly reflects income. Fort Howard Paper Co. v. Commissioner, 49 T.C. 275, 284 (1967); Photo-Sonics, Inc. v. Commissioner, 42 T.C. 926, 935 (1964), affd. 357 F.2d 656 (9th Cir. 1966); Klein Chocolate Co. v. Commissioner, 36 T.C. 142, 146 (1961), supplementing 32Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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