-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 inventoryPage: Previous 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 Next
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