Mountain State Ford Truck Sales, Inc., E.P. O'Meara, Tax Matters Person - Page 21




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          elected in the Form 970 to use the most recent purchases method,            
          and not any other proper method, in determining the current-year            
          cost of its parts pool.6                                                    
               In inventorying goods with respect to which a taxpayer                 
          elected the LIFO method, the taxpayer is required to (1) treat              
          those goods remaining on hand at the end of the taxable year as             
          being (a) those included in the opening inventory of the taxable            
          year, in the order of acquisition and to the extent thereof, and            
          (b) those acquired during the taxable year, sec. 472(b)(1); sec.            
          1.472-1(a), Income Tax Regs.; and (2) inventory them at cost,               
          sec. 472(b)(2); sec. 1.472-2(b), Income Tax Regs.                           
               There are two basic LIFO computational systems.  One is                
          based on specific goods (specific-goods LIFO method).  See sec.             
          1.472-2, Income Tax Regs.  The other is based on the dollars                
          invested in inventory and is known as the dollar-value LIFO                 
          method.  See sec. 1.472-8, Income Tax Regs.  Under the specific-            
          goods LIFO method, quantitative changes in inventory during the             
          year are measured in terms of an appropriate unit, such as                  
          pounds, pieces, or gallons.  The dollar-value LIFO method deter-            
          mines increases or deceases in inventory in terms of total                  

               6  The parties and their respective experts also disagree              
          about whether Mountain State Ford's method of using replacement             
          cost under the LIFO method complies with generally accepted                 
          accounting principles (GAAP) and conforms as nearly as may be to            
          the best accounting practice in Mountain State Ford's trade or              
          business, as required by sec. 471 and the regulations thereunder.           
          However, our resolution of the disagreement between the parties             
          about the clear-reflection-of-income standard makes it                      
          unnecessary for us to address the parties' and their respective             
          experts' dispute over GAAP.                                                 

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Last modified: May 25, 2011