- 18 - B.T. Babbitt, Inc. v. Commissioner, 32 B.T.A. 693, 696 (1935); Fletcher v. Commissioner, T.C. Memo. 1965-273. 3. Conclusion We conclude that petitioner may not amortize any of Cost Less' $175,000 payment for Jasiak's oral promise not to compete because petitioner and Jasiak did not intend to allocate any of the payment to the promise, and petitioner has not proven that Jasiak's promise had value. B. Inventory Adjustment Petitioners contend that Cost Less may reduce its ending inventory by $10,000 for each year in issue because, according to petitioners' estimate, Cost Less' inventory software overstated its ending inventory by that amount. We have long held that a taxpayer may adjust inventories to correctly reflect income. Elm City Nursery Co. v. Commissioner, 6 B.T.A. 89 (1927); Baumann Rubber Co. v. Commissioner, 4 B.T.A. 671 (1926). Petitioners do not explain how they computed the $10,000 amount. Petitioners appear to defend the $10,000 amount because the consumer price index (CPI) increased .185 percent on all items from January 1, 1988, to December 31, 1991. However, they did not show (1) how many of the 75,000 parts had price increases in any year; (2) how many parts remained in inventory at the end of the year for which the computer program increased costs; (3) the amount of price increases; (4) whatPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011