Mountain State Ford Truck Sales, Inc., E.P. O'Meara, Tax Matters Person - Page 7




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          sionally developed a new type of part.  However, from year to               
          year, only 10 percent to 15 percent of the parts numbers for                
          parts carried by Mountain State Ford changed.  For the parts                
          numbers that did change, Mountain State Ford could have deter-              
          mined the corresponding parts numbers for the year prior to the             
          change, but did not do so.                                                  
               While each different type of part that Mountain State Ford             
          carried in its parts inventory was assigned a part number, in               
          most instances each unit of a particular type of part was not               
          identified separately from every other unit of that same type of            
          part.  However, in some instances each unit of the same type of             
          certain large parts, such as engines, transmissions, and rear               
          axles, was identified not only by a part number, but also by a              
          serial number.                                                              
               Consistent with standard industry practice for heavy truck             
          dealers, Mountain State Ford maintained an inventory of parts by            
          using a computerized recordkeeping system which listed, inter               
          alia, the quantity of units on hand of each of the different                
          types of parts that it carried.  Mountain State Ford maintained             
          that system, which it referred to as its perpetual recordkeeping            
          system (perpetual inventory recordkeeping system), with the                 
          assistance of a company that provided computer services (computer           
          vendor) to businesses in the heavy truck dealer industry.  The              
          manufacturers authorized several computer vendors to assist heavy           
          truck dealers in the valuation of those dealers' parts invento-             
          ries.  Prior to 1994 Mountain State Ford utilized Ford's Dealer             

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Last modified: May 25, 2011