- 17 - making use of the LCM method of valuation highly impracticable and imprecise. Furthermore, the taxpayer in Atlantic Coast Realty failed to show that the inventorying of real estate was an established and accepted accounting practice. The Board held that taxpayers are not entitled to use the inventory method to account for real property. In W.C. & A.N. Miller Dev. Co. v. Commissioner, supra, the taxpayer, a real-estate developer, had applied for permission to change to the last-in-first-out (LIFO) method of valuing its inventory of houses constructed and held for sale. The taxpayer admitted that under Atlantic Coast Realty land costs could not be inventoried but contended that the houses on the land could be inventoried and that the job-cost method it had previously used to determine the gain or loss on the sale of each house was a specific identification inventory method of accounting. The Commissioner maintained that the job-cost method was merely a proper capitalization of tax taxpayer’s acquisition, development, construction, and other costs. We held that the taxpayer had failed to prove that it had previously used an inventory method of accounting and that the taxpayer had not shown that the use of inventories represented the best practice in its industry in accordance with generally accepted accounting principles. We further held that a finished house on a lot is not "merchandise" within the meaning of section 1.471-1, Income Tax Regs., and thatPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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