Mountain State Ford Truck Sales, Inc., E.P. O'Meara, Tax Matters Person - Page 17




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          method because it had used that method prior to adopting the LIFO           
          method and because that was the method used by the heavy truck              
          dealer industry.  In using replacement cost in valuing its parts            
          inventory under the LIFO method, Mountain State Ford was not                
          attempting to, and did not, determine or approximate the invoice            
          prices of the parts that it purchased.                                      
               On May 22, 1995, respondent issued a notice of final S                 
          corporation administrative adjustment (notice or FSAA) for 1991             
          to Mr. O'Meara, the tax matters person.  In the notice, respon-             
          dent did not terminate the elections that Mountain State Ford               
          made in the Form 970 to value its parts inventory under the                 
          dollar-value, link-chain LIFO method and to use the most recent             
          purchases method in determining the current-year cost of its                
          parts pool.  However, respondent determined in the notice that              
          the cost of goods sold reported in Mountain State Ford's 1991               
          return should be reduced, and the ordinary income reported in               
          that return should be increased, by $463,515.3  The amount of               
          that reduction and that increase was equal to the amount of the             
          LIFO reserve that Mountain State Ford had calculated over the               
          period 1980 through 1991 (LIFO reserve).  The adjustment at issue           
          in the notice thus was based on restoring to Mountain State                 
          Ford's income the amount of that LIFO reserve.  In making that              
          adjustment, respondent was unable to, and did not, recompute                
          Mountain State Ford's non-LIFO inventory value under a method               

               3  The parties settled the remaining adjustments in the                
          notice.                                                                     

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