E.W. Richardson - Page 37

                                       - 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

Last modified: May 25, 2011