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published by Ford" and for other manufacturers' parts on the
basis of "the dealer net prices as incorporated in the latest
dealer price lists published by the applicable manufacturer".
Nor did Mountain State Ford maintain inventory records which
showed the invoice price that it paid for each unit of each type
of part (1) delivered and/or returned to it and added to its
parts inventory and/or (2) sold by it and removed from that
inventory. However, Mountain State Ford did maintain other
records, such as accounts payable records and invoices, which
listed the invoice price paid by Mountain State Ford for each
unit of each type of part delivered to it.
After 1978, when Ford no longer owned any stock of Mountain
State Ford, Mountain State Ford was free to use an engagement
letter in employing a C.P.A. to audit its financial statements
and prepare its tax returns that was different from the letter
that it had previously used when Ford owned stock of Mountain
State Ford. Mountain State Ford also became free to adopt
accounting methods and/or procedures that were different from
those which it employed when it was owned by Ford, including its
method of valuing its parts inventory on the basis of replacement
cost, provided that it sought and received the consent of the
Internal Revenue Service before it made a change, inter alia, in
that method of valuing its parts inventory. After 1978, when
Ford no longer owned any stock of Mountain State Ford, Mountain
State Ford made no attempt to determine whether it could have
modified its perpetual inventory recordkeeping system so that it
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