- 22 - Commissioner, 439 U.S. 522, 531-532 (1979); Dayton Hudson Corp. & Subs. v. Commissioner, supra; sec. 1.471-2(a)(1) and (2), Income Tax Regs. We analyze these prongs seriatim, and we set forth our analysis below. Before doing so, however, we pause to summarize the qualifications of the experts. During the cases in chief, petitioners called two witnesses whom the Court recognized as experts, and respondent called three. We are given broad discretion to evaluate the cogency of each expert's analysis and to weigh it accordingly. See Trans City Life Ins. Co. v. Commissioner, 106 T.C. 274, 301 (1996). We must evaluate and weigh each expert's opinion in 8(...continued) Whenever, in the opinion of the Secretary the use of inventories is necessary in order clearly to determine the income of any taxpayer, inventories shall be taken by such taxpayer on such basis as the Secretary may prescribe as conforming as nearly as may be to the best accounting practice in the trade or business and as most clearly reflecting the income. The Commissioner has prescribed rules under sec. 471(a) for taxpayers like petitioners that employ a perpetual inventory system. In pertinent part, sec. 1.471-2(d), Income Tax Regs., provides: Where the taxpayer maintains book inventories in accordance with a sound accounting system in which the respective inventory accounts are charged with the actual cost of the goods purchased or produced and credited with the value of goods used, transferred, or sold, calculated upon the basis of the actual cost of the goods acquired during the taxable year (including the inventory at the beginning of the year), the net value as shown by such inventory accounts will be deemed to be the cost of the goods on hand. The balances shown by such book inventories should be verified by physical inventories at reasonable intervals and adjusted to conform therewith.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
Last modified: May 25, 2011