E.W. Richardson - Page 32

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          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 case             




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