Mountain State Ford Truck Sales, Inc., E.P. O'Meara, Tax Matters Person - Page 20




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          determining the current-year cost of its parts pool pursuant to             
          any other proper method under section 1.472-8(e)(2)(ii)(d),                 
          Income Tax Regs.5 (any other proper method), which petitioner               
          claims Mountain State Ford elected in the Form 970, does not                
          clearly reflect income.  Respondent agrees with petitioner's                
          framing of the issue relating to the clear-reflection-of-income             
          standard except that respondent contends that Mountain State Ford           

               4(...continued)                                                        
          inventory, respondent's adjustment in the notice to Mountain                
          State Ford's ordinary income for 1991 would be sustained.  Thus,            
          no issue regarding the price indices calculated by Mountain State           
          Ford under its link-chain method remains for our decision.                  
               5  Sec. 1.472-8(e)(2), Income Tax Regs., which describes the           
          double-extension method of computing the LIFO value of a dollar-            
          value pool, provides in pertinent part:                                     
                    (ii) The total current-year cost of items making                  
               up a pool may be determined--                                          
                         (a) By reference to the actual cost of                       
                    the goods most recently purchased or                              
                    produced;                                                         
                         (b) By reference to the actual cost of                       
                    the goods purchased or produced during the                        
                    taxable year in the order of acquisition;                         
                         (c) By application of an average unit                        
                    cost equal to the aggregate cost of all of                        
                    the goods purchased or produced throughout                        
                    the taxable year divided by the total number                      
                    of units so purchased or produced; or                             
                         (d) Pursuant to any other proper method                      
                    which, in the opinion of the Commissioner,                        
                    clearly reflects income.                                          
          Although sec. 1.472-8, Income Tax Regs., relating to the dollar-            
          value LIFO method does not discuss how the link-chain method that           
          Mountain State Ford elected in the Form 970 is to be applied, the           
          parties agree that sec. 1.472-8(e)(2)(ii), Income Tax Regs.,                
          applies to the link-chain method.                                           

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