-55-
Chevron, U.S.A., Inc. v. Natural Resources Defense Council, Inc.,
467 U.S. 837, 844 (1984).
Petitioner also contends that section 472 and its
predecessor provisions in the Internal Revenue laws have been
interpreted broadly and that the Court should interpret that
section broadly in this case and find that Consolidated's LIFO
method does not contravene it or the regulations thereunder. In
support of that contention, petitioner cites several cases,
including Hutzler Bros. Co. v. Commissioner, 8 T.C. 14, 29
(1947). We find all of those cases to be distinguishable and
petitioner's reliance on them to be misplaced. In the interest
of brevity, we shall discuss only the Hutzler Bros. Co. case.
Because of the number and diversity of the goods of the
taxpayer involved in Hutzler Bros. Co. v. Commissioner, supra,
the taxpayer, a department store retailer, devised a LIFO
inventory method that reduced the goods to their lowest common
denominator, viz, a dollar figure. That method, which is now
known as the dollar-value LIFO inventory method, was not
expressly permitted by regulation for the year before the Court
in the Hutzler Bros. Co. case. Hutzler Bros. Co. v.
Commissioner, supra at 24. The only method for that year that
was permitted by the regulations under section 22(d) of the 1939
Code as amended, a predecessor of section 472, was a method that
required the identification of specific goods in a taxpayer’s
inventory, a method known as the specific goods LIFO inventory
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