- 28 - expressed herein, and to the extent not discussed above, we find them to be without merit. The deficiencies set forth in the notices of deficiency are based on petitioner’s failure to recapture its LIFO reserves of $5,077,808 into its income. Based on our holding that $4,792,372, rather than $5,077,808, of the dealerships’ pre-S election LIFO reserves must be included in petitioner’s income, the tax deficiency is $408,300 (rather than $432,619), pursuant to respondent’s alternative position, for each of the years under consideration. Accordingly, Decision will be entered for respondent in the reduced amounts for the years under consideration.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Last modified: May 25, 2011