E.W. Richardson - Page 34

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               The Code and the regulations do not define the term “item”.            
          Amity Leather Prods. Co. v. Commissioner, 82 T.C. at 739-740;               
          Wendle Ford Sales, Inc. v. Commissioner, 72 T.C. at 455.                    
          However, we have previously addressed the definition of the term            
          for purposes of the dollar-value LIFO method.  See Hamilton                 
          Indus., Inc. & Sub. v. Commissioner, supra; Amity Leather Prods.            
          Co. v. Commissioner, supra; Wendle Ford Sales, Inc. v.                      
          Commissioner, supra.20                                                      
               In our prior cases, we have found that the proper definition           
          of an item for dollar-value LIFO purposes depends on the specific           
          facts and circumstances of the case.  Wendle Ford Sales, Inc. v.            
          Commissioner, supra at 459, 461.  Furthermore, we have found that           
          we must examine the facts and circumstances of the case in light            
          of the objectives of the dollar-value LIFO method.  See Hamilton            
          Indus., Inc. & Sub. v. Commissioner, supra at 135-136; Amity                
          Leather Prods. Co. v. Commissioner, supra at 733-734; Wendle Ford           
          Sales, Inc. v. Commissioner, supra at 458-459.                              
               A major objective of the LIFO method is to eliminate from              
          earnings any artificial profits resulting from inflationary                 
          increases in inventory costs.  Amity Leather Prods. Co. v.                  
          Commissioner, supra at 732.  Consequently, the dollar-value                 
          method is designed to ensure that any increase in the cost of               
          property passing through the inventory during the year is                   
          reflected in the cost of goods sold.  Hamilton Indus., Inc. &               

          20   See supra note 14.                                                     



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