-34-
(A) Only in inventorying goods * * *
specified in an application to use such meth-
od filed at such time and in such manner as
the Commissioner may prescribe * * *
* * * * * * *
(3) The change to, and the use of, such method
shall be in accordance with such regulations as the
Commissioner, with the approval of the Secretary, may
prescribe as necessary in order that the use of such
method may clearly reflect income.
Revenue Act of 1939 (1939 Act), ch. 247, sec. 219, 53 Stat. 877.
(We shall refer to section 22(d) of the 1939 Code as amended by
section 219 of the 1939 Act as section 22(d) of the 1939 Code as
amended.)
The regulations promulgated under section 22(d) of the 1939
Code as amended provided in pertinent part:
Sec. 19.22(d)-1. Inventories under elective
method.--Any taxpayer permitted or required to take
inventories * * * may elect with respect to those goods
specified in his application and properly subject to
inventory to compute his opening and closing
inventories in accordance with the method provided by
section 22(d), as amended. * * *
* * * * * * *
Sec. 19.22(d)-2. Requirements incident to adoption
and use of elective method.--* * *
(1) The taxpayer shall file an
application to use such method specifying
with particularity the goods to which it is
to be applied;
Secs. 19.22(d)-1 and -2, Regs. 103. In 1943, sections 19.22(d)-1
and -2 of Regulations 103 were repromulgated with changes not
pertinent here as sections 29.22(d)-1 and -2 of Regulations 111.
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