- 32 - T.C. 437 (1959); Advertisers Exch., Inc. v. Commissioner, 25 T.C. 1086, 1092 (1956), affd. 240 F.2d 958 (2d Cir. 1957). Investments defined its items of inventory for its new car pool by body size for taxable years 1974 through 1980. Despite this general body size definition of item, Investments treated the Escort model line as a separate item for taxable year 1980. This treatment of the Escort model line was inconsistent with its method of defining its items of inventory. Subsequently, in taxable year 1981, Investments began defining its items of inventory for its new car pool by model line. This definition of its items of inventory for its new car pool was inconsistent with its existing method of defining its items of inventory. In its new truck pool, Investments variously defined its items of inventory by body type (i.e., all vans as one item), load carrying ability, body size, and model line. Each change in the definition of its items of inventory for its new truck pool represented an inconsistent application of its method of defining its items of inventory. Investments’ inconsistent definition of its items of inventory for both its new car and new truck LIFO pools strikes at the heart of the requirement that a taxpayer’s inventory accounting must clearly reflect income. Investments’ inconsistent definition of its items of inventory violates the clear reflection rules of the Code, sec. 446(b), the regulations, secs. 1.471-2(b) and 1.472-8(a), Income Tax Regs., and our casePage: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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