E.W. Richardson - Page 35

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          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 the              




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