- 37 - 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.Page: 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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