-27- Respondent's Determinations Respondent mailed notices of final S corporation administrative adjustment (notices) for 1990 and 1991, respectively, to Merl Philip Long, grantor and trustee of the M.P. Long Living Trust, the tax matters person. Respondent determined in the notices that Consolidated improperly excluded customer cores from the calculation of its inventories under Consolidated's LIFO method for each of those years and that, consequently, Consolidated's LIFO election should be terminated. Respondent also determined in the notices that Consolidated did not reflect the proper amounts for customer cores in its inventories under Consolidated's FIFO-LCM method for each of those years.4 OPINION This case presents several inventory accounting issues that implicate sections 446, 471, and 472. Section 446 provides in pertinent part: (a) General Rule.--Taxable income shall be computed under the method of accounting on the basis of which the taxpayer regularly computes his income in keeping his books. (b) Exceptions.--If no method of accounting has been regularly used by the taxpayer, or if the method used does not clearly reflect income, the computation of taxable income shall be made under such method as, in the opinion of the Secretary, does clearly reflect income. 4 Petitioner conceded the remaining determination in the notice for 1990.Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
Last modified: May 25, 2011