E.W. Richardson - Page 31

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                    (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 32              





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