- 20 - 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.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011