Mountain State Ford Truck Sales, Inc., E.P. O'Meara, Tax Matters Person - Page 3




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               (2) Even though we have held that respondent did not abuse             
          respondent's discretion in making the determination described               
          above, did respondent abuse respondent's discretion by placing              
          Mountain State Ford on an impermissible method of inventory                 
          accounting when respondent adjusted Mountain State Ford's ordi-             
          nary income for 1991 to include the amount of the so-called LIFO            
          reserve that it had calculated during the period 1980 through               
          1991?  We hold that respondent did not.                                     
                                  FINDINGS OF FACT1                                   
               Some of the facts have been stipulated and are so found.               
               Mountain State Ford, which was incorporated in Delaware in             
          1968 and has been an S corporation since its taxable year 1987,             
          had its principal place of business in Denver, Colorado, at the             
          time the petition was filed.  E. P. O'Meara (Mr. O'Meara), who              
          worked in the automobile and truck dealer industry on a part-time           
          basis since late 1939 and on a full-time basis since January                
          1947, is Mountain State Ford's tax matters person.                          
               In January 1968, Mr. O'Meara started operating Mountain                
          State Ford as a heavy truck dealer under a management agreement             
          with Ford Motor Company (Ford), which owned all of its stock.  As           
          a heavy truck dealer for Ford, Mountain State Ford carried, and             
          maintained an inventory of, different types of heavy truck parts            

               1  Unless otherwise indicated, our Findings of Fact and                
          Opinion pertain to all periods since the incorporation of                   
          Mountain State Ford to the trial in this case; all section                  
          references are to the Internal Revenue Code (Code) in effect for            
          the year at issue; and all Rule references are to the Tax Court             
          Rules of Practice and Procedure.                                            

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