- 35 - Sub. v. Commissioner, supra at 132. To properly reflect increases attributable to inflation, we have noted that the goods contained in a taxpayer’s item categories must have similar characteristics, because a “system which groups like goods together and separates dissimilar goods permits cost increases attributable to inflation to be isolated and accurately measured.” Id. (fn. ref. omitted). Therefore, we have found that a “narrower definition of an item within a pool will generally lead to a more accurate measure of inflation (i.e., price index) and thereby lead to a clearer reflection of income.” Amity Leather Prods. Co. v. Commissioner, supra at 734. We have articulated another objective of dollar-value LIFO and a related consideration in determining the proper definition of an item. We have noted that the dollar-value LIFO method does not require the matching of specific goods in opening and closing inventories, but focuses on the total dollars invested in inventory. Wendle Ford Sales, Inc. v. Commissioner, supra at 458. Accordingly, minor modifications to an item should not cause the item to be treated as new or separate. Id. at 459. “This freedom from having to take into account minor technological changes in a product represents a major objective of the dollar-value approach.” Id. at 458. Thus, we have cautioned that the definition of an item of inventory must not be so narrow as to impose unreasonable administrative burdens upon a taxpayer, thus rendering impractical the taxpayer’s use of thePage: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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