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turing, Inc. v. Commissioner, supra. The Commissioner's discre-
tion under sections 446 and 471 is not unbridled, however. Thor
Power Tool Co. v. Commissioner, supra at 533; Consolidated
Manufacturing, Inc. v. Commissioner, supra. Even if a taxpayer's
accounting method does not result in a clear reflection of
income, the Commissioner may not change the taxpayer's accounting
method to another method that also fails to reflect income
clearly. Harden v. Commissioner, 223 F.2d 418, 421 (10th Cir.
1955), revg. 21 T.C. 781 (1954) and affg. Harden v. Hinds, 48
AFTR 1268, 54-1 USTC par. 9348 (W.D. Okla. 1954); Rotolo v.
Commissioner, 88 T.C. 1500, 1514 (1987).
As framed by petitioner, the question relating to the clear-
reflection-of-income standard is whether respondent abused
respondent's discretion in concluding that, in computing the LIFO
value of its dollar-value parts pool under the link-chain
method,4 Mountain State Ford's use of replacement cost in
4 The parties disputed at trial whether there are deficien-
cies in the manner in which Mountain State Ford computed the
price indices under its link-chain method. However, after trial
the parties entered into a second supplemental stipulation
regarding those price indices. According to that stipulation, in
the event that the Court were to sustain Mountain State Ford's
method of using replacement cost in computing the LIFO value of
its parts inventory, respondent's adjustment in the notice to
Mountain State Ford's ordinary income for 1991 would be reduced
from $463,515 to $53,870. That reduction would be made in that
event in order to reflect the parties' agreement in the second
supplemental stipulation to correct certain of the alleged
deficiencies that respondent had found in Mountain State Ford's
computation of the price indices under its link-chain method.
The parties further agreed in that stipulation that in the event
that the Court were not to permit Mountain State Ford's method of
using replacement cost in computing the LIFO value of its parts
(continued...)
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