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combination of the link-chain method and the index method to
price its LIFO inventories.21
Petitioner next argues that respondent’s proposed definition
of item is so narrow as to effectively require Investments to use
the specific goods LIFO method. We disagree with petitioner’s
assertion. Requiring Investments to use a model code definition
of item is not tantamount to placing Investments on the specific
goods method of LIFO, as the model code definition of an item
does not require Investments to match specific goods in opening
and closing inventory. Simply put, even though the definition of
an item is narrower, Investments is still free to use the dollar-
value LIFO method.
Finally, petitioner argues that the model code definition of
an item is too narrow, and that respondent abused her discretion
by requiring Investments to use that definition. Petitioner does
not specify why the model code definition of an item is too
narrow, and we have previously found that a narrower definition
of an item more clearly reflects income. Amity Leather Prods.
Co. v. Commissioner, supra at 734. Furthermore, since petitioner
has stipulated that Investments has all of the data necessary to
implement a model code definition of an item, petitioner cannot
21 We note that, in this case, the parties have stipulated that
Investments has never double extended a representative portion of
its new car and new truck inventory, but has always double
extended its entire inventory.
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